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Trilogy Metals Inc.

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FY2022 Annual Report · Trilogy Metals Inc.
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UNITED STATES 
SECURITIES AND EXCHANGE COMMISSION 
Washington, D.C. 20549 

FORM 10-K 

☒ 

☐ 

ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934 

TRANSITION REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934 

For the Fiscal Year Ended November 30, 2022 

OR 

For the Transition Period from       to 

Commission File Number: 1-35447 

TRILOGY METALS INC. 
(Exact Name of Registrant as Specified in Its Charter) 

British Columbia 
(State or Other Jurisdiction of 
Incorporation or Organization) 

Suite 1150, 609 Granville Street 
Vancouver, British Columbia 
Canada 
(Address of Principal Executive Offices) 

98-1006991 
(I.R.S. Employer 
Identification No.) 

V7Y 1G5 
(Zip Code) 

(604) 638-8088 
(Registrant’s Telephone Number, Including Area Code) 

Title of Each Class 
Common Shares, no par value 

Trading Symbol 
TMQ 

Name of Each Exchange on Which Registered 
NYSE AMERICAN 

Indicate by check mark if the registrant is a well-known seasoned issuer, as defined in Rule 405 of the Securities Act. Yes ☐ No ☒ 

Indicate by check mark if the registrant is not required to file reports pursuant to Section 13 or Section 15(d) of the Act. Yes ☐ No ☒ 

Securities registered pursuant to Section 12(g) of the Act: None 

Indicate by check mark whether the registrant (1) has filed all reports required to be filed by Section 13 or 15(d) of the Securities Exchange Act of 1934 during the 
preceding 12 months (or for such shorter period that the registrant was required to file such reports), and (2) has been subject to such filing requirements for the past 90 
days. Yes  ☒ No ☐ 

Indicate by check mark whether the registrant has submitted electronically every Interactive Data File required to be submitted pursuant to Rule 405 of Regulation S-

T during the preceding 12 months (or for such shorter period that the registrant was required to submit such files). Yes  ☒ No ☐ 

Indicate by check mark whether the registrant is a large accelerated filer, an accelerated filer, a non-accelerated filer, a smaller reporting company, or emerging growth 
company. See the definitions of “large accelerated filer,” “accelerated filer,” “smaller reporting company,” and “emerging growth company” in Rule 12b-2 of the Exchange 
Act. 
Large Accelerated Filer ☐ 

Smaller reporting company ☒ 

Emerging growth company ☐ 

Non-accelerated Filer ☒ 

Accelerated Filer ☐ 

If an emerging growth company, indicate by check mark if the registrant has elected not to use the extended transition period for complying with any new or revised 

financial accounting standards provided pursuant to Section 13(a) of the Exchange Act. ☐ 

Indicate by check mark whether the registrant has filed a report on and attestation to its management's assessment of the effectiveness of its internal control over 
financial reporting under Section 404(b) of the Sarbanes-Oxley Act (15 U.S.C. 7262(b)) by the registered public accounting firm that prepared or issued its audit report.  ☐ 

If securities are registered pursuant to Section 12(b) of the Act, indicate by check mark whether the financial statements of the registrant included in the filing reflect 

the correction of an error to previously issued financial statements. ☐ 

Indicate by check mark whether any of those error corrections are restatements that required a recovery analysis of incentive-based compensation received by any of 

the registrant’s executive officers during the relevant recovery period pursuant to § 240.10D-1(b). ☐ 

Indicate by check mark whether the registrant is a shell company (as defined in Rule 12b-2 of the Exchange Act). Yes ☐ No ☒ 

As at May 31, 2022, the aggregate market value of the registrant’s Common Shares held by non-affiliates was approximately $93.8 million. As of February 14, 2023, the 
registrant had 148,722,699 Common Shares, no par value, outstanding. 

Certain portions of the  registrant's definitive proxy statement to be  filed with the Securities and Exchange Commission pursuant to Regulation 14A not later than 
March 30, 2023, in connection with the registrant’s 2023 annual meeting of shareholders, are incorporated herein by reference into Part III of this Annual Report on Form 
10-K. 

DOCUMENTS INCORPORATED BY REFERENCE 

 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
     
     
 
 
 
 
 
 
 
 
 
 
 
TRILOGY METALS INC. 

TABLE OF CONTENTS 

CURRENCY  

FORWARD-LOOKING STATEMENTS  

PART I  

BUSINESS  

Item 1.  
Item 1A.   RISK FACTORS  
Item 1B.   UNRESOLVED STAFF COMMENTS  
Item 2.  
Item 3.  
Item 4.   MINE SAFETY DISCLOSURES  

PROPERTIES  
LEGAL PROCEEDINGS  

PART II  

Item 5.   MARKET FOR REGISTRANT’S COMMON EQUITY, RELATED STOCKHOLDER MATTERS AND 

ISSUER PURCHASES OF EQUITY SECURITIES  
SELECTED FINANCIAL DATA  

Item 6.  
Item 7.   MANAGEMENT’S DISCUSSION AND ANALYSIS OF FINANCIAL CONDITION AND RESULTS OF 

Item 8.  
Item 9.  

OPERATIONS  
FINANCIAL STATEMENTS AND SUPPLEMENTARY DATA  
CHANGES IN AND DISAGREEMENTS WITH ACCOUNTANTS ON ACCOUNTING AND FINANCIAL 
DISCLOSURE  

Item 9A.   CONTROLS AND PROCEDURES  
Item 9B.   OTHER INFORMATION  

PART III  

Item 10.   DIRECTORS, EXECUTIVE OFFICERS AND CORPORATE GOVERNANCE  
Item 11.   EXECUTIVE COMPENSATION  
Item 12.   SECURITY  OWNERSHIP  OF  CERTAIN  BENEFICIAL  OWNERS  AND  MANAGEMENT  AND  RELATED 

STOCKHOLDER MATTERS  

Item 13.   CERTAIN RELATIONSHIPS AND RELATED TRANSACTIONS, AND DIRECTOR INDEPENDENCE  
Item 14.   PRINCIPAL ACCOUNTANT FEES AND SERVICES  

PART IV  

Item 15.   EXHIBITS AND FINANCIAL STATEMENT SCHEDULES  
Item 16.  FORM 10-K SUMMARY 

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Unless the context otherwise requires, the words “we,” “us,” “our,” the “Company” and “Trilogy” refer to Trilogy Metals 
Inc., formerly NovaCopper Inc. (“Trilogy” or “Trilogy Metals”), a British Columbia corporation, either alone or together 
with its subsidiaries as the context requires, as of November 30, 2022. 

CURRENCY 

All dollar amounts are in United States currency unless otherwise stated. References to C$ or CDN$ refer to Canadian 
currency, and $ or US$ to United States currency. 

FORWARD-LOOKING STATEMENTS 

The information discussed in this Annual Report  on Form 10-K includes “forward-looking information” and “forward-
looking statements” within the meaning of Section 21E of the Securities Exchange Act of 1934 (the “Exchange Act”), and 
applicable  Canadian  securities  laws.  These  forward-looking  statements  may  include  statements  regarding  perceived 
merit of properties, exploration results and budgets, mineral reserves and resource estimates, work programs, capital 
expenditures,  operating  costs,  cash  flow  estimates,  production  estimates  and  similar  statements  relating  to  the 
economic viability of a  project, timelines, strategic plans, statements relating anticipated activity with respect to the 
Ambler  Mining  District  Industrial  Access  Project  (“Ambler  Access  Project”  or  “AAP”),  the  Company’s  plans  and 
expectations relating to the Upper Kobuk Mineral Projects (as defined herein), completion of transactions, market prices 
for precious and base metals, the results of the NI 43-101 Arctic Report and S-K 1300 Arctic Report (as defined herein) 
or other statements that are not statements of fact. These statements relate to analyses and other information that are 
based on forecasts of future results, estimates of amounts not yet determinable and assumptions of management. 

Statements concerning mineral resource estimates may also be deemed to constitute “forward-looking statements” to 
the extent that they involve estimates of the mineralization that will be encountered if the property is developed. Any 
statements  that  express  or  involve  discussions  with  respect  to  predictions,  expectations,  beliefs,  plans,  projections, 
objectives, assumptions or future events or performance (often, but not always, identified by words or phrases such as 
“expects”, “is expected”, “anticipates”, “believes”,  “plans”, “projects”, “estimates”, “assumes”, “intends”, “strategy”, 
“goals”, “objectives”, “potential”, “possible” or variations thereof or stating that certain actions, events, conditions or 
results “may”, “could”, “would”, “should”, “might” or “will” be  taken, occur or be achieved, or the negative of any of 
these  terms  and  similar  expressions)  are  not  statements  of  historical  fact  and  may  be  forward-looking  statements. 
Forward-looking statements are subject to a variety of known and unknown risks, uncertainties and other factors that 
could cause actual events or results to differ from those reflected in the forward-looking statements, including, without 
limitation: 

• 

• 

• 

• 

• 

• 

risks related to the COVID-19 pandemic; 

risks related to inability to define proven and probable reserves; 

risks related to our ability to finance the development of our mineral properties through external financing, 
strategic alliances, the sale of property interests or otherwise; 

uncertainty as to whether there will ever be production at the Company’s mineral exploration and development 
properties; 

risks  related  to  our  ability  to  commence  production  and  generate  material  revenues  or  obtain  adequate 
financing for our planned exploration and development activities; 

risks related to lack of infrastructure including but not limited to the risk whether or not the  Ambler Access 
Project will receive the requisite permits and, if it does, whether the Alaska Industrial Development and Export 
Authority (“AIDEA”) will build the AAP; 

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• 

• 

• 

• 

• 

• 

• 

• 

risks related to inclement weather which may delay or hinder exploration activities at our mineral properties; 

risks related to our dependence on a third party for the development of our projects; 

none of the Company’s mineral properties are in production or are under development; 

commodity price fluctuations; 

uncertainty related to title to our mineral properties; 

our history of losses and expectation of future losses; 

risks  related  to  increases  in  demand  for  equipment,  skilled  labor  and  services  needed  for  exploration  and 
development of mineral properties and related cost increases; 

uncertainties relating to the assumptions underlying our resource estimates, such as metal pricing, metallurgy, 
mineability, marketability and operating and capital costs; 

uncertainty related to inferred, indicated and measured mineral resources; 

•  mining and development risks, including risks related to infrastructure, accidents, equipment breakdowns, labor 

disputes or other unanticipated difficulties with or interruptions in development, construction or production; 

• 

• 

• 

• 

• 

• 

• 

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• 

• 

• 

uncertainty related to successfully acquiring commercially mineable mineral rights; 

risks and uncertainties relating to the interpretation of drill results, the geology, grade and continuity of our 
mineral deposits; 

risks related to governmental regulation and permits, including environmental regulation, including the risk that 
more stringent requirements or standards may be adopted or applied due to circumstances unrelated to the 
Company and outside of our control; 

the  risk  that  permits  and  governmental  approvals  necessary  to  develop  and  operate  mines  at  our  mineral 
properties will not be available on a timely basis or at all; 

risks related to the need for reclamation activities on our properties and uncertainty of cost estimates related 
thereto; 

risks related to the acquisition and integration of operations or projects; 

risks  related  to  industry  competition  in  the  acquisition  of  exploration  properties  and  the  recruitment  and 
retention of qualified personnel; 

our need to attract and retain qualified management and technical personnel; 

risks related to conflicts of interests of some of our directors and officers; 

risks related to potential future litigation; 

risks related to market events and general economic conditions; 

risks related to future sales or issuances of equity securities decreasing the value of existing Trilogy common 
shares (“Common Shares”), diluting voting power and reducing future earnings per share; 

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• 

• 

• 

• 

• 

• 

• 

risks related to the voting power of our major shareholders and the impact that a sale by such shareholders may 
have on our share price; 

uncertainty as to the volatility in the price of the Company’s Common Shares; 

the Company’s expectation of not paying cash dividends; 

adverse  federal  income  tax  consequences  for  U.S.  shareholders  should  the  Company  be  a  passive  foreign 
investment company; 

risks related to global climate change; 

risks related to adverse publicity from non-governmental organizations; 

uncertainty as to our ability to maintain the adequacy of internal control over financial reporting as per the 
requirements of Section 404 of the Sarbanes-Oxley Act (“SOX”); and 

increased regulatory compliance costs, associated with rules and regulations promulgated by the United States 
Securities  and  Exchange  Commission  (“SEC”),  Canadian  Securities  Administrators,  the  NYSE  American,  the 
Toronto  Stock  Exchange  (“TSX”),  and  the  Financial  Accounting  Standards  Boards,  and  more  specifically,  our 
efforts to comply with the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank”). 

This  list  is  not  exhaustive  of  the  factors  that  may  affect  any  of  our  forward-looking  statements.  Forward-looking 
statements are statements about the future and are inherently uncertain, and our actual achievements or other future 
events or conditions may differ materially from those reflected in the forward-looking statements due to a variety of 
risks, uncertainties and other factors, including, without limitation, those referred to in this report under the heading 
“Risk Factors” and elsewhere. 

Our forward-looking statements are based on the beliefs, expectations and opinions of management on the date the 
statements  are  made.  In  connection  with  the  forward-looking  statements  contained  herein,  we  have  made  certain 
assumptions about our business, including about: 

• 

• 

• 

• 

• 

• 

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• 

• 

• 

our ability to achieve production at our Arctic and Bornite Projects (as defined herein); 

the accuracy of our mineral resource estimates; 

the results, costs and timing of future exploration drilling and engineering; 

timing and receipt of approvals, consents and permits under applicable legislation; 

the adequacy of our financial resources; 

the receipt of third party contractual, regulatory and governmental approvals for the exploration, development, 
construction and production of our properties; 

our expected ability to develop adequate infrastructure and that the cost of doing so will be reasonable; 

continued good relationships with South32 (as defined below), local communities and other stakeholders; 

there being no significant disruptions affecting operations, whether relating to labor, supply, power, damage to 
equipment or other matters; 

expected trends and specific assumptions regarding metal prices and currency exchange rates; and 

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prices for and availability of fuel, electricity, parts and equipment and other key supplies remaining consistent 
with current levels. 

We have also assumed that no significant events will occur outside of our normal course of business. Although we have 
attempted to identify important factors that could cause actual actions, events or results to differ materially from those 
described in forward-looking statements, there may be other factors that cause actions, events or results not to be as 
anticipated, estimated or intended. We believe that the assumptions inherent in the forward-looking statements are 
reasonable as of the date hereof. However, forward-looking statements are not guarantees of future performance and, 
accordingly, undue reliance should not be put on such statements due to the inherent uncertainty therein. We do not 
assume any obligation to update forward-looking statements if circumstances or management’s beliefs, expectations or 
opinions should change, except as required by law. For the reasons set forth above, investors should not place undue 
reliance  on  forward-looking  statements.  All  forward-looking  statements  contained  herein  are  qualified  by  these 
cautionary statements. 

TECHNICAL INFORMATION 

Richard Gosse, a Qualified Person under NI 43-101 and an employee and Vice President Exploration of the Company has 
reviewed and approved the scientific and technical information contained in this Annual Report on Form 10-K. 

Item 1.     BUSINESS 

PART I 

Our principal business is the exploration and development of the Upper Kobuk Mineral Projects (“Upper Kobuk Mineral 
Projects” or  “UKMP” or “UKMP Projects”) located in the Ambler mining district in Northwest Alaska, United States. The 
Upper  Kobuk  Mineral  Projects  are  held  by  Ambler  Metals  LLC  (“Ambler  Metals”),  a  limited  liability  company  owned 
equally  by  Trilogy  and  South32  Limited,  and  is  comprised  of  the  (i) Arctic  Project,  which  contains  a  high-grade 
polymetallic volcanogenic massive sulfide (“VMS”) deposit (“Arctic Project”); and (ii) Bornite Project, which contains a 
carbonate-hosted  copper  -  cobalt  deposit  (“Bornite  Project”).  Our  goals  include  expanding  mineral  resources  and 
advancing the UKMP Projects through technical, engineering and feasibility studies so that production decisions can be 
made on those projects.  Our interest in Ambler Metals is held by a wholly-owned subsidiary, NovaCopper US Inc. (dba 
Trilogy Metals US) (“Trilogy Metals US”), registered to do business in the State of Alaska. We also conduct early-stage 
exploration through a wholly owned subsidiary, 995 Exploration Inc. 

Name, Address and Incorporation 

Trilogy  Metals  Inc.  was  incorporated  on  April 27,  2011  under  the  name  NovaCopper  Inc.  pursuant  to  the  terms  of 
the Business  Corporations  Act (British  Columbia).  NovaCopper  Inc.  changed  its  name  to  Trilogy  Metals  Inc.  on 
September 1, 2016 to better reflect its diversified metals resource base. Our registered office is located at Suite 2600, 
Three Bentall Centre, 595 Burrard Street, Vancouver, British Columbia, Canada, and our executive office is located at 
Suite 1150, 609 Granville Street, Vancouver, British Columbia, Canada. 

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Corporate Organization Chart 

The following chart depicts our corporate structure together with the jurisdiction of incorporation of our subsidiaries at 
November 30, 2022. All ownership is 100% unless otherwise stated.  

On  February  11,  2020,  the  Company’s  Upper  Kobuk  Mineral  Projects  were  transferred  to  Ambler  Metals,  a  newly 
incorporated limited liability company incorporated under the laws of Delaware. Each of Trilogy and South32 hold a 50% 
interest in Ambler Metals. All mineral resources and mineral reserve estimates with respect to the Arctic Project and 
Bornite Project that are disclosed in this Annual Report  on Form 10-K are reported on a 100% basis unless otherwise 
noted. See “Significant Developments in 2020”. 

Business Cycle 

Our business, at its current exploration phase, is cyclical. Exploration activities are conducted primarily during snow-free 
months in Alaska. The optimum field season at the Upper Kobuk Mineral Projects is from late May to late September. 
The length of the snow-free season at the Upper Kobuk Mineral Projects varies from about May through November at 
lower elevations and from July through September at higher elevations. 

Trilogy’s Strategy 

Our  business strategy  is  focused  on  creating  value  for stakeholders  through  our  ownership  and  advancement  of  the 
Arctic Project and exploration  and advancement  of the Bornite Project  with our joint  venture partner, South32, and 
through the pursuit of similarly attractive mining projects. We plan to: 

• 

advance the Arctic Project towards development with key activities including increased definition of the NI 43-
101 mineral resources and reserves contained in the Arctic FS, additional metallurgical and geotechnical studies 
and the advancement of baseline environmental studies; 

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• 

advance  exploration  in  the  Ambler  mining  district  and,  in particular,  at  the  Bornite  Project,  pursuant  to  the 
NANA Agreement (as more particularly described under “History of Trilogy – Agreement with NANA Regional 
Corporation”) through resource development and initial technical studies; and 

• 

pursue project level or corporate transactions that are value accretive. 

Significant Developments in 2022 

•  On January 11, 2022, the Company announced the 2022 program and budget of approximately $28.5 million 
for  the  advancement  of  the  Upper  Kobuk  Mineral  Projects  (“UKMP”)  located  in  Northwestern  Alaska.  The 
budget is 100% funded by Ambler Metals. 

•  On January 20, 2022, the Company announced an updated mineral resource for the Bornite Project. 

•  On February 7, 2022, the Company announced that the AIDEA had formally approved the proposed plan and 
budget for the 2022 summer field season activities and services of up to $30.8 million for the Ambler Access 
Project.  The cost will be shared 50/50 by AIDEA and Ambler Metals. 

•  On February 23, 2022, the Company announced that the United States Department of the Interior (“DOI”) filed 
a motion to remand the Final Environmental Impact Statement (“FEIS”) and suspend the right-of-way permits 
issued to AIDEA for the Ambler Access Project. The DOI has stated that the suspension of the road permits will 
allow it to carry out additional supplemental work on the FEIS.   The motion also indicated that the DOI has 
requested  that  the  lawsuits  filed  against  the  DOI  by  a  coalition  of  national  and  Alaska  environmental  non-
government organizations be suspended.  The lawsuits had been filed in response to the United States Bureau 
of Land Management’s (“BLM”) issuance of the Joint Record of Decision (“JROD”), that authorized a right-of-
way across federally managed lands for AIDEA and the AAP. 

•  On June 8, 2022, the Company announced that Ambler Metals had commenced mobilization for the upcoming 

exploration field program at the UKMP. 

•  On September 21, 2022, the Company announced that the BLM had published in the Federal Register a Notice 
of Intent (“NOI”) that it will prepare a Supplemental Environmental Impact Statement (“SEIS”) for the proposed 
Ambler Mining District Industrial Access Road. The NOI indicates that: 

• 

• 

• 

The BLM will accept comments related to the SEIS for 45 days so that the BLM can determine which, if 
any,  additional  impacts  and  resources  related  to  identified  deficiencies  should  be  more  thoroughly 
assessed to facilitate integrating the BLM’s National Environmental Policy Act (“NEPA”) analysis with 
its  ongoing  Alaska  National  Interest  Lands  Conservation  Act  Section  810  and  National  Historic 
Preservation Act Section 106 processes; 

Input by Alaska Native Tribes and Corporations will continue to be of critical importance and that BLM 
will continue to consult with these entities under applicable guidance; and 

Preparation of the SEIS in compliance with NEPA will additionally help the BLM to fulfill its obligations 
under applicable law. 

•  On November 23, 2022, the Company announced that the BLM submitted a status report in accordance with 
the Voluntary Remand dated May 17, 2022 stating that the comment period ended on November 4, 2022 for 
the scoping process of the SEIS and that the BLM currently anticipates publishing a draft SEIS during the second 
quarter  of  calendar  year  2023,  which  will  be  open  for  public  comment  upon  publication.  The  BLM  also 
anticipates  publishing  a  final  SEIS,  conducting  final  pre-decision  consultation  with  Alaska  Native  Tribes  and 
Corporations, and issuing a Record of Decision, all within the fourth quarter of calendar year 2023. 

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Significant Developments in 2021 

•  On January 6, 2021, the BLM, the National Park Service and the AIDEA signed Right-of-Way agreements giving 
AIDEA the ability to cross federally  owned and managed lands along the route for the Ambler  Road Project 
approved in the Joint Record of Decision. The agreements grant a 50-year right-of-way on federally owned and 
managed land by the federal agencies for the future development of the Ambler Mining District Industrial Access 
Road. The authorizing documents with the two agencies are the final federal permits required for the Ambler 
Road Project. 

• 

• 

• 

In a press release dated February 11, 2021, the Company announced its approval for Ambler Metals to enter 
into an Ambler Access Development Agreement (the “Development Agreement”) with AIDEA. The Development 
Agreement defines how AIDEA and Ambler Metals will work cooperatively together on the pre-development 
work for the Ambler Access Project to address funding and oversight of the project’s feasibility and permitting 
activities until the parties reach a decision on the construction of the project. The cost of the pre-development 
work and activities will be paid 50% by AIDEA and 50% by Ambler Metals based on an annually agreed program 
and  budget.  Under  the  Development  Agreement,  Ambler  Metals  and  AIDEA  agree  to  contribute  up  to  $35 
million each for pre-development costs of the Ambler Access Project through December 31, 2024. 

In a press release dated April 19, 2021, the Company announced that the AIDEA had formally approved the 
proposed plan and budget for the 2021 summer field season activities and services of up to $13 million for the 
Ambler  Access  Project.  The  cost  was  to  be shared  50/50  by  AIDEA  and  Ambler  Metals.  The  Board  of  AIDEA 
authorized up to $6.5 million for field season activities. These funds were to be matched by up to another $6.5 
million from Ambler Metals under the terms of the Ambler Access Development Agreement that was approved 
by the AIDEA Board on February 10, 2021 and subsequently executed by both parties, resulting in a total budget 
for 2021 of up to $13 million. The AAP is a proposed 211-mile, east-west running controlled industrial access 
road that would provide industrial access to the Ambler Mining District in northwestern Alaska. 

In a press release dated May 17, 2021, the Company announced that Ambler Metals had finalized the details of 
the 2021 exploration field program at the UKMP for the previously approved $27 million exploration budget. 
The exploration program was aligned with a strategy developed by the Company and South32 which prioritizes 
the exploration budget  within the UKMP. The strategy defines a  program that advances the highest priority 
projects and exploration targets, both VMS and Carbonate-Hosted Copper (“CHC”), ranging from early-stage 
geophysical anomalies that were identified during the 2019 airborne Versatile Time Domain Electromagnetic 
(“VTEM”) survey to advanced VMS and CHC prospects with historical resources. The site camp opened on June 
1, 2021. 

Significant Developments in 2020 

•  On April 10, 2017, we entered into an option agreement, as amended (the “South32 Option Agreement”) with 
South32  Group  Operations  Pty  Ltd  (“South32  Operations”),  a  wholly-owned  subsidiary  of  South32  Limited, 
which  agreement  was  later  assigned  by  South32  Operations  to  its  affiliate,  South32  USA  Exploration  Inc. 
(together with South32 Operations, “South32”). The South32 Option Agreement granted to South32 a three-
year option to form a 50/50 joint venture with respect to Trilogy’s Alaskan assets which includes the Upper 
Kobuk Mineral Projects. South32 was required to contribute a minimum of $10 million each year, for a maximum 
of three years, to keep the option in good standing (the “Initial Funding”). If South32 elected to exercise the 
option, the subscription price less certain deductions for Initial Funding was to be paid in one tranche within 45 
business days. Had South32 not made its annual minimum payment or elected to withdraw, the option would 
lapse and South32 would have no claim to ownership or to the funds it had already spent. In order to exercise 
its option to form the Joint Venture, South32 was required to contribute a minimum of $150 million, plus (i) any 
amounts Trilogy spent on matched parallel funding to a maximum of $16 million over the three year period and 
(ii)  $10  million,  less  the  amount  of  the  Initial  Funding  contributed  by  South32.  On  December  19,  2019,  we 

9 

 
announced in a press release that South32 had exercised its option to acquire a 50% interest in a joint venture 
company to be named “Ambler Metals LLC” which now owns the UKMP Projects. 

•  On February 11, 2020, we announced that the formation of Ambler Metals had completed, with the Company 
contributing  its  assets  associated  with  the  UKMP  Projects,  and  South32  contributing  a  subscription  price 
payment of US$145 million, to the joint venture. 

• 

• 

In a press release dated February 26, 2020, the Company announced that Ambler Metals had approved a 2020 
program budget of $22.8 million for the advancement of the UKMP Projects. The budget was to be 100% funded 
by  Ambler  Metals.  The  2020  program  budget  included  10,000  meters  of  drilling  at  the  Arctic  Project,  2,500 
meters of drilling within the Ambler VMS belt and geological mapping and geochemical soil sampling  at the 
Bornite Project.  

Subsequent to the approval of the 2020 program budget, the Company and its joint venture partner, South32, 
decided  not  to  proceed  with  the  2020  exploration  program  after  assessing  the  coronavirus  (COVID-19) 
environment. Ambler Metals gave due consideration to the merits of carrying out an abridged work program at 
the  UKMP  Projects.  However,  given  the  continued  uncertainty  resulting  from  COVID-19,  ongoing  safety 
concerns (despite added safety protocols including physical distancing, protective equipment and testing) and 
the fact that, due to COVID-19, the planned field season had already been delayed to the point at which any 
field season would provide limited critical path benefits, the decision was made not to proceed with a 2020 field 
season.  

•  On April 20, 2020, we issued a press release announcing the appointment of Tony Giardini as President and 
Chief Executive Officer effective June 1, 2020. Mr. Giardini has been a director of the Company since 2012 when 
the  Company  was  formed  and  will  continue  to  be  an  executive  director.  James  (Jim)  Gowans,  the  Interim 
President and Chief Executive Officer, remained in his role as a director of the Company.  

• 

• 

In a press release dated July 23, 2020, the Company, along with our joint venture partner, South32, announced 
the signing of the Record of Decision by BLM for the Ambler Access Project. The Record of Decision approves 
the development of the northern route, which is to be a 211-mile private gravel access road in the southern 
Brooks Range foothills to provide industrial access to the Ambler Mining District. 

In a press release dated August 20, 2020, the Company announced the positive results of its feasibility study for 
the Arctic Project (the “2020 Arctic FS”). The 2020 Arctic FS was prepared on a 100% ownership basis, of which 
Trilogy’s  share  is  50%.  The  2020  Arctic  FS  describes  the  technical  and  economic  viability  of  establishing  a 
conventional open-pit copper-zinc-lead-silver-gold mine and mill complex for a 10,000 tonne per day operation 
for a minimum 12-year mine life. See the 2020 Arctic Report (as defined below) and “Properties” for additional 
information.  

•  On August 25, 2020, we issued a press release to announce that the board of Ambler Metals had appointed 
Ramzi Fawaz as President and Chief Executive Officer of Ambler Metals effective as of September 1, 2020. Mr 
Fawaz  joined  Ambler  Metals  from  Newmont  Corporation  (“Newmont”)  where  he  was  Senior  Vice  President 
Projects  from  February  2011  to  October  2019,  with  responsibility  for  the  development  and  execution  of 
Newmont’s major gold and copper projects globally.  

•  On September 3, 2020, we issued a press release announcing that the Company had hired Richard Gosse as Vice 

President Exploration of the Company with immediate effect.  

•  On October 2, 2020, we filed the technical report for the Company’s Arctic Project entitled “Arctic Feasibility 
Study Alaska, USA NI 43-101 Technical Report" with an effective date of August 20, 2020, prepared by Ausenco 
Engineering Canada Inc., Wood Canada Limited and SRK Consulting (Canada) Inc. (the “2020 Arctic Report”). 
The  technical  report  describes  the  2020  Arctic  FS  on  the  Arctic  Project  as  discussed  above.  The  2020  Arctic 
Report has been superseded by the Company’s NI 43-101 Arctic Report (as defined below). 

10 

•  On  November  19,  2020,  we  issued  a  press  release  announcing  that  Ambler  Metals  had  approved  the  2021 
program and budget of approximately $27 million for the advancement of the UKMP Projects. The budget will 
be 100% funded by Ambler Metals. 

History of Trilogy 

Spin-Out 

We were formerly a wholly-owned subsidiary of NovaGold Resources Inc. (“NovaGold”). In April 2012, Trilogy Common 
Shares were distributed to NovaGold shareholders pursuant to a Plan of Arrangement under the Companies Act (Nova 
Scotia) and were listed and posted for trading on the TSX and on the NYSE American. 

Name Change 

We changed our corporate name to Trilogy Metals Inc. from NovaCopper Inc. in 2016 to better reflect the diversity of 
minerals at our UKMP Projects. On September 8, 2016, upon the opening of the markets our shares began trading on 
the TSX and the NYSE American under the symbol “TMQ”. 

Agreement with NANA Regional Corporation 

On  October  19,  2011,  NANA  Regional  Corporation,  Inc.  (“NANA”),  an  Alaska  Native  Corporation  headquartered  in 
Kotzebue, Alaska, and Trilogy Metals US entered an Exploration Agreement and Option Agreement  (as amended, the 
“NANA Agreement”) for the  cooperative development  of NANA’s respective resource interests in the Ambler mining 
district  of Northwest  Alaska.  Upon the formation of Ambler Metals, the  Company assigned its rights and obligations 
under the NANA Agreement to Ambler Metals.  The NANA Agreement consolidates Ambler Metals’ and NANA’s land 
holdings into an approximately 142,831-hectare land package and provides a framework for the exploration and any 
future development of this high-grade and prospective poly-metallic belt.  

The NANA Agreement grants Ambler Metals the nonexclusive right to enter on, and the exclusive right to explore, the 
Bornite lands and the Alaska Native Claims Settlement Act (“ANCSA”) lands (each as defined in the NANA Agreement) 
and in connection therewith, to construct and utilize temporary access roads, camps, airstrips and other incidental works.  
In  consideration  for  this  right,  Trilogy  Metals  US  previously  paid  to  NANA  $4  million  in  cash.    Ambler  Metals  is  also 
required to make payments to NANA for scholarship purposes in accordance with the terms of the NANA Agreement.  
Ambler  Metals  has  further  agreed  to  use  reasonable  commercial  efforts  to  train  and  employ  NANA  shareholders  to 
perform work for Ambler Metals in connection with its operations on the Bornite lands, ANCSA lands and Ambler lands 
(as defined in the NANA Agreement) (collectively, the “Lands”). The NANA Agreement has a term of 20 years, with an 
option  in  favour  of  Ambler  Metals  to  extend  the  term  for  an  additional  10 years.  The  NANA  Agreement  may  be 
terminated  by  mutual  agreement  of  the  parties  or  by  NANA  if  Ambler  Metals  does  not  meet  certain  expenditure 
requirements on the Bornite lands and ANCSA lands. 

If, following receipt of a feasibility study and the release for public comment of a related draft environmental impact 
statement, Ambler Metals decides to proceed with construction of a mine on the Lands, Ambler Metals will notify NANA 
in writing and NANA will have 120 days to elect to either (a) exercise a  non-transferrable back-in-right  to acquire an 
undivided ownership interest between 16% and 25% (as specified by NANA) of that specific project; or (b) not exercise 
its back-in-right, and instead receive a net proceeds royalty equal to 15% of the net proceeds realized by Ambler Metals 
from such project (following the recoupment by Ambler Metals of all costs incurred, including operating, capital and 
carrying costs). The cost to exercise such back-in-right is equal to the percentage interest in the project multiplied by the 
difference  between  (i)  all  costs  incurred  by  Ambler  Metals  or  its  affiliates  on  the  project,  including  historical  costs 
incurred prior to the date of the NANA Agreement together with interest on the costs; and (ii) $40 million (subject to 
exceptions). This amount will be payable by NANA to Ambler Metals in cash at the time the parties enter into a joint 
venture agreement and in no event will the amount be less than zero.  

11 

In the event that NANA elects to exercise its back-in-right, the parties will as soon as reasonably practicable form a joint 
venture, with NANA’s interest being between 16% to 25% and Ambler Metals owning the balance of the interest in the 
joint venture. Upon formation of the joint venture, the joint venture will assume all of the obligations of Ambler Metals 
and  be  entitled  to  all  the  benefits  of  Ambler  Metals  under  the  NANA  Agreement  in  connection  with  the  mine  to  be 
developed and the related Lands. A party’s failure to pay its proportionate share of costs in connection with the joint 
venture will result in dilution of its interest. Each party will have a right of first refusal over any proposed transfer of the 
other party’s interest in the joint venture other than to an affiliate or for the purposes of granting security.  A transfer 
by either party of any net proceeds royalty interest in a project other than for financing purposes will also be subject to 
a first right of refusal. A transfer of NANA’s net smelter return on the Lands is subject to a first right of refusal by Ambler 
Metals. 

In connection with possible development of a mine on the Bornite lands or ANCSA lands, Ambler Metals and NANA will 
execute a mining lease to allow Ambler Metals or the joint venture to construct and operate a mine on the Bornite lands 
or ANCSA lands. These leases will provide NANA a 2% net smelter royalty as to production from the Bornite lands and a 
2.5% net smelter royalty as to production from the ANCSA lands. If Ambler Metals decides to proceed with construction 
of a  mine on the Ambler lands, NANA will enter into a  surface use agreement  with Ambler Metals which  will afford 
Ambler Metals access to the  Ambler lands along routes approved by NANA on the Bornite lands or ANCSA lands. In 
consideration  for  the  grant  of  such  surface  use  rights,  Ambler  Metals  will  grant  NANA  a  1%  net  smelter  royalty  on 
production  and  an  annual  payment  of  $755  per  acre  (as  adjusted  for  inflation  each  year  beginning  with  the  second 
anniversary of the effective date of the NANA Agreement and for each of the first 400 acres (and $100 for each additional 
acre) of the lands owned by NANA and used for access which are disturbed and not reclaimed. 

Ambler  Metals  has  formed  an  oversight  committee  with  NANA,  which  consists  of  four  representatives  from  each  of 
Ambler Metals and NANA (the “Oversight Committee”). The Oversight Committee is responsible for certain planning and 
oversight matters carried out by us under the NANA Agreement.  The planning and oversight matters that are the subject 
of the NANA Agreement will be determined by majority vote.  The representatives of each of Ambler Metals and NANA 
attending a meeting will have one vote in the aggregate and in the event of a tie, the Ambler Metals representatives 
jointly shall have a deciding vote on all matters other than Subsistence Matters, as that term is defined in the NANA 
Agreement.  There shall be no deciding vote on Subsistence Matters and Ambler Metals may not proceed with such 
matters unless approved by majority vote of the Oversight Committee or with the consent of NANA, such consent not 
to be unreasonably withheld or delayed. 

Principal Markets 

We do not currently have a principal market. Our principal objective is to become a producer of copper. 

Specialized Skill and Knowledge 

All  aspects  of  our  business  require  specialized  skills  and  knowledge.  Such  skills  and  knowledge  include  the  areas  of 
geology, mining and accounting. See “Executive Officers of Trilogy” for details as to the specific skills and knowledge of 
our directors and management. 

Environmental Protection 

Mining is an extractive industry that impacts the environment.  Along with our joint venture partner, South32, our goal 
is to evaluate ways to minimize that impact and to develop safe, responsible and profitable operations by developing 
natural  resources  for  the  benefit  of  our  employees,  shareholders  and  communities  and  maintain  high  standards  for 
environmental performance at the UKMP Projects.  We strive to meet or exceed environmental standards at the UKMP 
Projects.  One way Ambler Metals does this is through collaborations with local communities in Alaska, including Native 
Alaskan groups.  Ambler Metals’ environmental performance will be overseen at the Ambler-board and Trilogy-board 
level and environmental performance is the responsibility of the project manager. All new activities and operations will 
be  managed  for  compliance  with  applicable  laws  and  regulations.    In  the  absence  of  regulation,  best  management 

12 

practices will be applied to manage environmental risk. Furthermore, we will strive to limit releases to the air, land or 
water and appropriately treat and dispose of waste. 

For a more detailed discussion of the various government laws and regulations applicable to our operations and potential 
negative  effects  of  these  laws  and  regulations,  see  Item  1A.  Risk  Factors,  and  Item  2  Properties,  Environmental, 
Permitting, Social and Closure Considerations below. 

Employees 

As  of  November  30,  2022,  we  had  5  full-time  employees,  all  of  whom  were  employed  at  our  executive  office  in 
Vancouver, BC.  We have entered into executive employment agreements with the CEO and CFO (each as defined herein).  
In the past, the number of individuals we employed fluctuated throughout the year depending on the season; however, 
during 2020, we contributed the UKMP Projects to Ambler Metals and no longer directly employ any seasonal staff. 

Information About Our Executive Officers 

As  of  November  30,  2022,  we  had  two  executive  officers,  namely  Tony  Giardini  and  Elaine  Sanders.    The  following 
information is presented as of November 30, 2022. 

      Age        Held Office Since 
June 1, 2020(1) 

63  

53  

January 30, 2012(2) 

Name and Residence 
Tony Giardini 
British Columbia, 
Canada 
Director, President and 
Chief Executive Officer 

Elaine Sanders 
British Columbia, 
Canada 
VP, Chief Financial 
Officer and Corporate 
Secretary 

Business Experience During Past Five Years  
Chief Executive Officer of Trilogy (2020 
– present); President of Ivanhoe Mines 
Ltd. (May 2019 – March 2020); Chief 
Financial Officer of Kinross Gold 
Corporation (December 2012 - April 
2019) 
Vice President and Chief Financial 
Officer of Trilogy (2012 – present); 
Corporate Secretary of Trilogy (2011 – 
present) 

(1)  Mr. Giardini was appointed President and Chief Executive Officer on June 1, 2020. 
(2)  Ms. Sanders was appointed Chief Financial Officer on January 30, 2012.  She became a  full-time employee of the 

Company on November 13, 2012. 

Competitive Conditions 

The  mineral  exploration  and  development  industry  is  competitive  in  all  phases  of  exploration,  development  and 
production.  There  is  a  high  degree  of  competition  faced  by  us  in  Alaska  and  elsewhere  for  skilled  management 
employees, suitable contractors for drilling operations, technical and engineering resources, and necessary exploration 
and mining equipment, and many of these competitor companies have greater financial resources, operational expertise, 
and/or more advanced properties than us. Additionally, our operations are in a remote location where skilled resources 
and support services are limited. We have in place experienced management personnel and continue to  evaluate the 
required expertise and skills to carry out our operations. As a result of this competition, we may be unable to achieve 
our exploration and development in the future on terms we consider acceptable or at all. See “Item 1A. Risk Factors.” 

Available Information 

We make available, free of charge, on or through our website, at www.trilogymetals.com our Annual Report on Form 10-
K, which includes our audited financial statements, our Quarterly Reports on Form 10-Q, and our Current Reports on 
Form 8-K and amendments to those reports filed or furnished pursuant to Section 13(a) or 15(d) of the Exchange Act. 

13 

      
 
 
 
 
 
 
 
 
 
 
 
The  SEC  maintains  a  website  that  contains  reports,  proxy  and  information  statements,  and  other  information  at 
www.sec.gov. Our website and the information contained therein or connected thereto are not intended to be, and are 
not incorporated into this Annual Report on Form 10-K. 

Item 1A.  RISK FACTORS 

Investing in our securities is speculative and involves a high degree of risk due to the nature of our business and the 
present stage of exploration of our mineral properties. The following risk factors, as well as risks currently unknown to 
us, could materially adversely affect our future business, operations and financial condition and could cause them to 
differ  materially  from  the  estimates  described  in  forward-looking  information  relating  to  Trilogy,  or  our  business, 
property or financial results, each of which could cause purchasers of securities to lose all or part of their investments. 

Risks Related to the COVID Pandemic  

The outbreak of the coronavirus (COVID-19) may affect our operations. 

The  Company  faces  risks  related  to  health  epidemics  and  other  outbreaks  of  communicable  diseases,  which  could 
significantly disrupt its operations and may materially and adversely affect its business and financial conditions. 

The Company’s business could be adversely impacted by the effects of the coronavirus or other epidemics. In December 
2019, a novel strain of the coronavirus (COVID-19) emerged in China and the virus has now spread around the world, 
including Canada and the U.S. The extent to which COVID-19 impacts the Company’s business, including exploration and 
development activities at Ambler Metals and the market for its securities, will depend on future developments, which 
are uncertain and cannot be predicted at this time, and include the duration, severity and scope of the outbreak and the 
actions taken to contain or treat the coronavirus outbreak. In particular, the continued spread of the coronavirus and 
travel and other restrictions established to curb the spread of the COVID-19, has and could continue to materially and 
adversely  impact  the  Company’s  business  including  without  limitation,  the  planned  exploration  programs  at  Ambler 
Metals (see “Significant Developments in 2020” above), employee health, workforce productivity, increased insurance 
premiums, limitations on travel, the availability of industry experts and personnel, the timing to process drill and other 
metallurgical testing, interruption of supplies from third parties upon which the Company relies  and other factors that 
will depend on future developments beyond the Company’s control, which may have a material and adverse effect on 
the its business, financial condition and results of operations. 

There can be no assurance that the Company's personnel will not be impacted by these pandemic diseases and ultimately 
see its workforce productivity reduced or incur increased medical costs or insurance premiums as a result of these health 
risks. 

Risks Related to the Company’s Mineral Properties 

We may not have sufficient funds to develop our mineral projects or to complete further exploration programs. 

We have limited financial resources. We currently generate no mining operating  revenue and must primarily finance 
exploration activity and the development of mineral projects by other means. Although South32 funded Ambler Metals 
in the amount of US$145 million upon formation of the joint venture as discussed above, in the future, once our share 
of such amount has been expended or we wish to acquire any other properties outside of Ambler Metals, our ability to 
continue  exploration,  development  and  production  activities,  if  any,  will  depend  on  our  ability  to  obtain  additional 
external financing. Any unexpected costs, problems or delays could severely impact our ability to continue exploration 
and development activities. The failure to meet ongoing obligations on a timely basis could result in a loss or a substantial 
dilution of our interests in projects. 

The sources of external financing that we may use for these purposes include project  or bank  financing or public or 
private offerings of equity and debt. In addition, we may enter into one or more strategic alliances or joint ventures, in 
addition  to  our  joint  venture  with  South32,  sell  marketable  securities  held  by  the  Company,  decide  to  sell  certain 

14 

property interests, or utilize one or a combination of all of these alternatives. The financing alternative we choose may 
not be available on acceptable terms, or at all. If additional financing is not available, we may have to postpone further 
exploration or development of, or sell our interest in, one or more of our principal properties. 

Even if one of our mineral projects is determined to be economically viable to develop into a mine, such development may 
not be successful. 

If the development of one of our projects is found to be economically feasible and approved by our Board  and in the 
case of the UKMP Projects, by our joint venture partner, South32, such development will require obtaining permits and 
financing, the construction and operation of mines, processing plants and related infrastructure, including road access. 
As a result, we are and will continue to be subject to all of the risks associated with establishing new mining operations, 
including: 

• 

• 

• 

• 

• 

• 

• 

the  timing  and  cost,  which  can  be  considerable,  of  the  construction  of  mining  and  processing  facilities  and 
related infrastructure; 

the availability and cost of skilled labor and mining equipment; 

the availability and cost of appropriate smelting and refining arrangements; 

the need to obtain necessary environmental and other governmental approvals and permits and the timing of 
the receipt of those approvals and permits; 

the availability of funds to finance construction and development activities; 

potential opposition from non-governmental organizations, environmental groups or local groups which may 
delay or prevent development activities; and 

potential increases in construction and operating costs due to changes in the cost of fuel, power, materials and 
supplies. 

The costs, timing and complexities of developing our projects may be greater than anticipated because our property 
interests  are  not  located  in  developed  areas,  and,  as  a  result,  our  property  interests  are  not  currently  served  by 
appropriate  road  access,  water  and  power  supply  and  other  support  infrastructure.  Cost  estimates  may  increase 
significantly as more detailed engineering work is completed on a project. It is common in new mining operations to 
experience unexpected costs, problems and delays during construction, development  and mine start-up. In addition, 
delays in the early stages of mineral production often occur. Accordingly, we cannot provide assurance that we will ever 
achieve, or that our activities will result in, profitable mining operations at the UKMP Projects or any other property that 
we may acquire.  

In  addition,  there  can  be  no  assurance  that  our  mineral  exploration  activities  will  result  in  any  discoveries  of  new 
mineralization.  If  further  mineralization  is  discovered  there  is  also  no  assurance  that  the  mineralization  would  be 
economical  for  commercial  production.  Discovery  of  mineral  deposits  is  dependent  upon  a  number  of  factors  and 
significantly influenced by the technical skill of the exploration personnel involved. The commercial viability of a mineral 
deposit is also dependent upon a number of factors which are beyond our control, including the attributes of the deposit, 
commodity prices, government policies and regulation and environmental protection. 

The Upper Kobuk Mineral Projects are located in a remote area of Alaska, and access to them is limited. Exploration and 
any  future  development  or  production  activities  may  be  limited  and  delayed  by  infrastructure  challenges,  inclement 
weather and a shortened exploration season. 

We cannot provide assurances that the proposed AAP that would provide access to the Ambler mining district will be 
built, that it will be built in a timely manner, that the cost of accessing the proposed road will be reasonable, that it will 

15 

be built in the manner contemplated, or that it will sufficiently satisfy the requirements of the Upper Kobuk Mineral 
Projects.  The  proposed  AAP  requires  significant  permitting  and  approvals,  and  the  JROD  issued  in  2020  is  currently 
subject to lawsuits which could delay or prevent the project. Further, changes in the U.S. federal administration may 
result in changes in interpretations or priorties which may further delay or prevent the proposed AAP. 

In addition, successful development of the Upper Kobuk Mineral Projects will require the development of the necessary 
infrastructure. If adequate infrastructure is not available in a timely manner, there can be no assurance that: 

• 

• 

• 

the development of the Upper Kobuk Mineral Projects will be commenced or completed on a timely basis, if at 
all; 

the resulting operations will achieve the anticipated production volume; or 

the  construction  costs  and  operating  costs  associated  with  the  development  of  the  Upper  Kobuk  Mineral 
Projects will not be higher than anticipated. 

As the Upper Kobuk Mineral Projects are located in a remote area, exploration, development and production activities 
may be limited and delayed by inclement weather and a shortened exploration season. The exploration of the UKMP 
Projects has also been impacted by COVID-19. See “Risks Related to COVID-19” above. 

We are dependent on a third party that participates in exploration and development of our Upper Kobuk Mineral Projects. 

In December 2019, South32 exercised its option to acquire a 50% interest in Ambler Metals. The formation of Ambler 
Metals was completed in February 2020 and Ambler Metals now owns the Upper Kobuk Mineral Projects. Our success 
with respect to the Upper Kobuk Mineral Projects depends on the efforts and expertise of South32 with whom we have 
contracted; we hold a 50% interest and the remaining 50% interest is held by South32, who is not under our control or 
direction. We are dependent on them for the progress and development of the Upper Kobuk Mineral Projects. South32 
may also have different priorities which could impact the timing and cost of development of the Upper Kobuk Mineral 
Projects.  The third party may also be in default of its agreement with us, without our knowledge, which may put the 
mineral property and related assets at risk. The existence or occurrence of one or more of the following circumstances 
and events could have a material adverse impact on our ability to achieve our business plan, profitability, or the viability 
of our interests held with the third party, which could have a material adverse impact on our business, future cash flows, 
earnings, results of operations and financial condition: (i) disagreement with our business partner on how  to develop 
and operate the Upper Kobuk Mineral Projects efficiently; (ii) inability to exert influence over certain strategic decisions 
made  in  respect  of  the  jointly-held  Upper  Kobuk  Mineral  Projects;  (iii) inability  of  our  business  partner  to  meet  its 
obligations to the joint business or third parties; and (iv) litigation with our business partner regarding joint business 
matters. 

We have no history of production and no revenue from mining operations. 

We have a very limited history of operations and to date have generated no revenue from mining operations. As such, 
we are subject to many risks common to such enterprises, including under-capitalization, cash shortages, limitations with 
respect to personnel, financial and other resources and lack of significant revenues. There is no assurance that the Upper 
Kobuk  Mineral  Projects,  or  any  other  future  projects  will  be  commercially  mineable,  and  we  may  never  generate 
revenues from our mining operations. 

Changes in the market price of copper, zinc and other metals, which in the past have fluctuated widely, will affect our 
ability  to  finance  continued  exploration  and  development  of  our  projects  and  affect  our  operations  and  financial 
condition. 

Our long-term viability will depend, in large part, on the market price of copper, zinc and other metals. The market prices 
for these metals are volatile and are affected by numerous factors beyond our control, including: 

16 

• 

• 

• 

• 

• 

• 

global or regional consumption patterns; 

the supply of, and demand for, these metals; 

speculative activities; 

the availability and costs of metal substitutes; 

expectations for inflation; and 

political and economic conditions, including interest rates and currency values. 

We cannot predict the effect of these factors on metal prices. A decrease in the market price of copper, zinc and other 
metals could affect our ability to raise funds to finance the exploration and development of any of our mineral projects, 
which would have a material adverse effect on our financial condition and results of operations. The market price of 
copper,  zinc  and  other  metals  may  not  remain  at  current  levels.  In  particular,  an  increase  in  worldwide  supply,  and 
consequent  downward  pressure  on  prices,  may  result  over  the  longer  term  from  increased  copper  production  from 
mines developed or expanded as a result of current metal price levels. There is no assurance that a profitable market 
may exist or continue to exist. 

Title and other rights to our properties may be subject to challenge. 

We cannot provide assurance that title to our properties will not be challenged. We (through our interest in Ambler 
Metals) indirectly own mineral claims which constitute our property holdings. We may not have, or may not be able to 
obtain, all necessary surface rights to develop a property. Title insurance is generally not available for mineral properties 
and  our  ability  to  ensure  that  we  have  obtained  a  secure  claim  to  individual  mining  properties  may  be  severely 
constrained. Our mineral properties may be subject to prior unregistered agreements, transfers or claims, and title may 
be affected by, among other things, undetected defects. We have not conducted surveys of all of the claims in which we 
hold direct or indirect interests. A successful claim contesting our title to a property will cause us to lose our rights to 
explore and, if warranted, develop that property or undertake or continue production thereon. This could result in our 
not being compensated for our prior expenditures relating to the property. In addition, our ability to continue to explore 
and  develop  the  property  may  be  subject  to  agreements  with  other  third  parties  including  agreements  with  native 
corporations and first nations groups, for instance, the lands at the Upper Kobuk Mineral Projects are subject to the 
NANA  Agreement  (as  more  particularly  described  under  "History  of  Trilogy  -  Agreement  with  NANA  Regional 
Corporation"). 

We will incur losses for the foreseeable future. 

We  expect  to  incur  losses  unless  and  until  such  time  as  our  mineral  projects  generate  sufficient  revenues  to  fund 
continuing  operations.  The  exploration  and  development  of  our  mineral  properties  will  require  the  commitment  of 
substantial financial resources that may not be available. 

The amount and timing of expenditures will depend on a number of factors, including the progress of ongoing exploration 
and development, the results of consultants’ analyses and recommendations, the rate at which  operating losses are 
incurred, the execution of any joint venture agreements with strategic partners and the acquisition of additional property 
interests, some of which are beyond our control. We cannot provide assurance that we will ever achieve profitability. 

High metal prices in past years have encouraged increased mining exploration, development and construction activity, 
which has increased demand for, and cost of, exploration, development and construction services and equipment. 

The relative strength of metal prices in past years has encouraged increases in mining exploration, development and 
construction  activities  around  the  world,  which  has  resulted  in  increased  demand  for,  and  cost  of,  exploration, 
development and construction services and equipment. Increased demand for and cost of services and equipment could 

17 

result in delays if services or equipment cannot be obtained in a timely manner due to inadequate availability and may 
cause scheduling difficulties due to the need to coordinate the availability of services or equipment, any of which could 
materially increase project exploration, development and/or construction costs. 

Risks Relating to the Mining Industry and Mineral Reserves 

Mineral resource and reserve calculations are only estimates. 

Any  figures  presented  for  mineral  resources  or  reserves  in  this  Form 10-K  and  in  our  other  filings  with  securities 
regulatory authorities and those which may be presented in the future are and will only be estimates. There is a degree 
of uncertainty attributable to the calculation of mineral reserves and mineral resources. Until mineral reserves or mineral 
resources are actually mined and processed, the quantity of metal and grades must be considered as estimates only and 
no assurances can be given that the indicated levels of metals will be produced. In making determinations about whether 
to advance any of our projects to development, we must rely upon estimated calculations as to the mineral resources or 
reserves and grades of mineralization on our properties. 

The  estimating  of  mineral  reserves  and  mineral  resources  is  a  subjective  process  that relies  on  the  judgment  of  the 
persons  preparing  the  estimates.  The  process  relies  on  the  quantity  and  quality  of  available  data  and  is  based  on 
knowledge, mining experience, analysis of drilling results and industry practices. Valid estimates made at a given time 
may  significantly  change  when  new  information  becomes  available.  While  we  believe  that  the  mineral  resource 
estimates  included  in  this  Form 10-K  for  the  Upper  Kobuk  Mineral  Projects  are  well-established  and  reflect 
management’s best estimates, by their nature mineral resource estimates are imprecise and depend, to a certain extent, 
upon analysis of drilling results and statistical inferences that may ultimately prove to be inaccurate. There can be no 
assurances that actual results will meet the estimates contained in feasibility studies or pre-feasibility studies. As well, 
further studies are required. 

Estimated mineral reserves or mineral resources may have to be recalculated based on changes in metal prices, further 
exploration or development activity or actual production experience. This could materially and adversely affect estimates 
of the volume or grade of mineralization, estimated recovery rates or other important factors that influence mineral 
reserve or mineral resource estimates. The extent to which mineral resources may ultimately be reclassified as mineral 
reserves is dependent upon the demonstration of their profitable recovery. Any material changes in mineral resource 
estimates  and  grades  of  mineralization  will  affect  the  economic  viability  of placing  a  property  into  production  and a 
property’s return on capital. We cannot provide assurance that mineralization can be mined or processed profitably. 

Our mineral resource estimates have been determined and valued based on assumed future metal prices, cut-off grades 
and operating costs that may prove to be inaccurate. Extended declines in market prices for copper, zinc, lead, gold and 
silver may render portions of our mineralization uneconomic and result in reduced reported mineral resources, which in 
turn  could  have  a  material  adverse  effect  on  our  results  of  operations  or  financial  condition.  We  cannot  provide 
assurance that mineral recovery rates achieved in small scale tests will be duplicated in large scale tests under on-site 
conditions or in production scale. 

A reduction in any mineral reserves that may be estimated by us could have an adverse impact on our future cash flows, 
earnings, results of operations and financial condition. No assurances can be given that any mineral resource estimates 
for the Upper Kobuk Mineral Projects will ultimately be reclassified as mineral reserves. See “Cautionary Note to United 
States Investors.” 

Significant uncertainty exists related to inferred mineral resources. 

There  is  a  risk  that  inferred  mineral  resources  referred  to  in  this  Form 10-K  cannot  be  converted  into  measured  or 
indicated mineral resources as there may be limited ability to assess geological continuity. It is reasonably expected that 
the majority of inferred mineral resources could be upgraded to indicated mineral resources with continued exploration. 
See “Cautionary Note to United States Investors.” 

18 

Mining is inherently risky and subject to conditions or events beyond our control. 

The development and operation of a mine is inherently dangerous and involves many risks that even a combination of 
experience, knowledge and careful evaluation may not be able to overcome, including: 

• 

unusual or unexpected geological formations; 

•  metallurgical and other processing problems; 

•  metal losses; 

• 

• 

• 

• 

• 

• 

environmental hazards; 

power outages; 

labor disruptions; 

industrial accidents; 

periodic interruptions due to inclement or hazardous weather conditions; 

flooding, explosions, fire, rockbursts, cave-ins and landslides; 

•  mechanical equipment and facility performance problems; and 

• 

the availability of materials and equipment. 

These risks could result in damage to, or destruction of, mineral properties, production facilities or other properties, 
personal injury or death, including to our employees, environmental damage, delays in mining, increased production 
costs, asset write downs, monetary losses and possible legal liability. We may not be able to obtain insurance to cover 
these risks at economically feasible premiums, or at all. The Company's insurance premiums have increased in recent 
years  and  in  other  circumstances  the  scope  of  insurance  coverage  has  been  reduced.  The  Company  also  expects 
insurance premiums to increase due to the impacts of COVID-19. Insurance against certain environmental risks, including 
potential liability for pollution and other hazards associated with mineral exploration and production, is not generally 
available to companies within the mining industry. We may suffer a material adverse effect on our business if we incur 
losses related to any significant events that are not covered by our insurance policies. 

We cannot provide assurance that we will successfully acquire commercially mineable mineral rights. 

Exploration for and development of copper properties involves significant financial risks which even a combination of 
careful  evaluation,  experience  and  knowledge  may  not  eliminate.  While  the  discovery  of  an  ore  body  may  result  in 
substantial rewards, few properties which are explored are ultimately developed into producing mines. Major expenses 
may  be  required  to  establish  reserves  by  drilling,  constructing  mining  and  processing  facilities  at  a  site,  developing 
metallurgical processes and extracting metals from ore. We cannot ensure that our current exploration and development 
programs will result in profitable commercial mining operations. 

The economic feasibility of development projects is based upon many factors, including the accuracy of mineral resource 
estimates;  metallurgical  recoveries;  capital  and  operating  costs;  government  regulations  relating  to  prices,  taxes, 
royalties, land tenure, land use, importing and exporting  and environmental protection; and metal prices, which  are 
highly  volatile.  Development  projects  are  also  subject  to  the  successful  completion  of  feasibility  studies,  issuance  of 
necessary governmental permits and availability of adequate financing. 

Most exploration projects do not result in the discovery of commercially mineable ore deposits, and no assurance can 
be  given  that  any  anticipated  level  of  recovery  of  ore  reserves,  if  any,  will  be  realized  or  that  any  identified  mineral 

19 

deposit will ever qualify as a commercially mineable (or viable) ore body which can be legally and economically exploited. 
Estimates of mineral reserves, mineral resources, mineral deposits and production costs can also be affected by such 
factors  as  environmental  permitting  regulations  and  requirements,  weather,  environmental  factors,  unforeseen 
technical difficulties, the metallurgy of the mineralization forming the mineral deposit, unusual or unexpected geological 
formations and work interruptions. If current exploration programs do not result in the discovery of commercial ore, we 
may need to write-off part or all of our investment in our existing exploration stage properties and may need to acquire 
additional properties. 

Material changes in mineral reserves, if any, grades, stripping ratios or recovery rates may affect the economic viability 
of any project. Our future growth and productivity will depend, in part, on our ability to develop commercially mineable 
mineral rights at our existing properties or identify and acquire other commercially mineable mineral rights, and on the 
costs and results of continued exploration and potential development programs. Mineral exploration is highly speculative 
in nature and is frequently non-productive. Substantial expenditures are required to: 

• 

• 

• 

establish mineral  resources and reserves through drilling and metallurgical and other testing techniques; 

determine metal content and metallurgical recovery processes to extract metal from the ore; and 

construct, renovate or expand mining and processing facilities. 

In  addition,  if  we  discover  ore,  it  would  take  several  years  from  the  initial  phases  of  exploration  until  production  is 
possible. During this time, the economic feasibility of production may change. As a result of these uncertainties, there 
can be no assurance that we will successfully acquire commercially mineable (or viable) mineral rights. 

Risks Relating to Government Regulation 

We are subject to significant governmental regulations. 

Our  exploration  activities  are  subject  to  extensive  federal,  state,  provincial  and  local  laws  and  regulations  governing 
various matters, including: 

• 

• 

• 

• 

• 

• 

• 

environmental protection; 

the management and use of toxic substances and explosives; 

the management of natural resources; 

the exploration and development of mineral properties, including reclamation; 

exports; 

price controls; 

taxation and mining royalties; 

•  management of tailing and other waste generated by operations; 

• 

• 

• 

labor standards and occupational health and safety, including mine safety; 

historic and cultural preservation; and 

transportation. 

20 

Failure to comply with applicable laws and regulations may result in civil or criminal fines or penalties or enforcement 
actions, including orders issued by regulatory or judicial authorities enjoining, curtailing or closing operations or requiring 
corrective measures, installation of additional equipment or remedial actions, any of which could result in significant 
expenditures. We may also be required to compensate private parties suffering loss or damage by reason of a breach of 
such laws, regulations or permitting requirements. It is also possible that future laws and regulations, or more stringent 
enforcement of current laws and regulations by governmental authorities, could cause us to incur additional expense or 
capital expenditure restrictions, suspensions or closing of our activities and delays in the exploration and development 
of our properties. 

We  require  further  permits  in  order  to conduct  current  and  anticipated  future  operations,  and delays  in  obtaining  or 
failure to obtain such permits, or a failure to comply with the terms of any such permits that we have obtained, would 
adversely affect our business. 

Our  current  and  anticipated  future  operations,  including  further  exploration,  development  and  commencement  of 
production on our mineral properties, require permits from various governmental authorities. Obtaining or renewing 
governmental permits is a complex and time-consuming process. The duration and success of efforts to obtain and renew 
permits are contingent upon many variables not within our control. Due to the preliminary stages of the Upper Kobuk 
Mineral Projects, it is difficult to assess what specific permitting requirements will ultimately apply. 

Shortage of qualified and experienced personnel in the U.S. federal and Alaskan State agencies to coordinate a federally 
led joint environmental impact statement process could result in delays or inefficiencies. Backlog within the permitting 
agencies could affect the permitting timeline or potential of the Upper Kobuk Mineral Projects, as may negative public 
perception of mining projects in general due to circumstances unrelated to the Company and outside of its control. Other 
factors that could affect the permitting timeline include (i) the number of other large-scale projects currently in a more 
advanced stage of development which could slow down the review process for the Upper Kobuk Mineral Projects and 
(ii) significant public response regarding the Upper Kobuk Mineral Projects. 

We cannot provide assurance that all permits that we require for our operations, including any for construction of mining 
facilities or conduct of mining, will be obtainable or renewable on reasonable terms, or at all. Delays or a failure to obtain 
such required permits, or the expiry, revocation or failure to comply with the terms of any such permits that we have 
obtained, would adversely affect our business. 

Our activities are subject to environmental laws and regulations that may increase our costs and restrict our operations. 

All  of  our  exploration,  potential  development  and  production  activities  are  subject  to  regulation  by  governmental 
agencies  under  various  environmental  laws.  These  laws  address  emissions  into  the  air,  discharges  into  water, 
management  of  waste,  management  of  hazardous  substances,  protection  of  natural  resources,  antiquities  and 
endangered species and reclamation of lands disturbed by mining operations. Environmental legislation is evolving, and 
the  general  trend  has  been  towards  stricter  standards  and  enforcement,  increased  fines  and  penalties  for 
noncompliance,  more  stringent  environmental  assessments  of  proposed  projects  and  increasing  responsibility  for 
companies and their officers, directors and employees. Compliance with environmental laws and regulations may require 
significant capital outlays on our behalf and may cause material changes or delays in our intended activities. 

Several regulatory initiatives are currently ongoing within the State of Alaska that have the potential to influence the 
permitting process for the Upper Kobuk Mineral Projects. These include revisions to Alaska's Water Quality Standards 
regarding  mixing  zones  regulations,  which  are  currently  under  Environmental  Protection  Agency  review,  and  which 
revisions may be required in order to authorize a mixing zone for discharge in Subarctic Creek. Future changes in these 
laws or regulations could have a significant adverse impact on some portion of our business, requiring us to re-evaluate 
those activities at that time. 

21 

Environmental hazards may exist  on our properties that are unknown to us at the present  time and that have been 
caused by previous owners or operators or that may have occurred naturally. We may be liable for remediating such 
damage. 

Failure  to  comply  with  applicable  environmental  laws,  regulations  and  permitting  requirements  may  result  in 
enforcement actions thereunder, including orders issued by regulatory or judicial authorities, causing operations to cease 
or  to  be  curtailed,  and  may  include  corrective  measures  requiring  capital  expenditures,  installation  of  additional 
equipment or remedial actions. 

Land reclamation requirements for our exploration properties may be burdensome. 

Land reclamation requirements are  generally  imposed on mineral exploration companies (as well as companies with 
mining operations) in order to minimize long term effects of land disturbance. Reclamation may include requirements 
to: 

• 

• 

• 

treat ground and surface water to applicable water quality standards; 

control dispersion of potentially deleterious effluents; and 

reasonably re-establish pre-disturbance landforms and vegetation. 

In order to carry out reclamation obligations imposed on us in connection with exploration, potential development and 
production activities, we must  allocate financial resources  that might otherwise be spent  on further exploration and 
development programs. In addition, regulatory changes could increase our obligations to perform reclamation and mine 
closing activities. If we are required to carry out unanticipated reclamation work, our financial position could be adversely 
affected. 

Risks Related to the Acquisition of New Projects 

Risks inherent in acquisitions of new properties. 

We  may  actively  pursue  the  acquisition  of  exploration,  development  and  production  assets  consistent  with  our 
acquisition and growth strategy. From time to time, we may also acquire securities of or other interests in companies 
with respect to which we may enter into acquisitions or  other transactions. Acquisition transactions involve inherent 
risks, including but not limited to: 

• 

• 

• 

• 

• 

• 

• 

• 

accurately assessing the value, strengths, weaknesses, contingent and other liabilities and potential profitability 
of acquisition candidates; 

ability to achieve identified and anticipated operating and financial synergies; 

unanticipated costs; 

diversion of management attention from existing business; 

potential loss of our key employees or key employees of any business acquired; 

unanticipated  changes  in  business,  industry  or  general  economic  conditions  that  affect  the  assumptions 
underlying the acquisition; 

decline in the value of acquired properties, companies or securities; 

assimilating the operations of an acquired business or property in a timely and efficient manner; 

22 

•  maintaining our financial and strategic focus while integrating the acquired business or property; 

• 

• 

implementing uniform standards, controls, procedures and policies at the acquired business, as appropriate; 
and 

to the extent that we make an acquisition outside of markets in which it has previously operated, conducting 
and managing operations in a new operating environment. 

Acquiring additional businesses or properties could place increased pressure on our cash flow if such acquisitions involve 
a  cash  consideration.  The  integration  of  our  existing  operations  with  any  acquired  business  will  require  significant 
expenditures of time, attention and funds. Achievement of the benefits expected from consolidation would require us 
to incur significant costs in connection with, among other things, implementing financial and planning systems. We may 
not be able to integrate the operations of a recently acquired business or restructure our previously existing business 
operations without encountering difficulties and delays. In addition, this integration may require significant attention 
from  our  management  team,  which  may  detract  attention  from  our  day-to-day  operations.  Over  the  short-term, 
difficulties associated with integration could have a material adverse effect on our business, operating results, financial 
condition  and  the  price  of  our  Common  Shares.  In  addition,  the  acquisition  of  mineral  properties  may  subject  us  to 
unforeseen liabilities, including environmental liabilities, which could have a material adverse effect on us. There can be 
no assurance that any future acquisitions will be successfully integrated into our existing operations. 

Any one or more of these factors or other risks could cause us not to realize the anticipated benefits of an acquisition of 
properties or companies and could have a material adverse effect on our financial condition. 

We face industry competition in the acquisition of exploration properties and the recruitment and retention of qualified 
personnel. 

We  compete  with  other  exploration  and  producing  companies,  many  of  which  are  better  capitalized,  have  greater 
financial resources, operational experience and technical capabilities or are further advanced in their development or 
are significantly larger and have access to greater mineral reserves, for the acquisition of mineral claims, leases and other 
mineral interests as well as for the recruitment and retention of qualified employees and other personnel. If we require 
and are unsuccessful in acquiring additional mineral properties or in recruiting and retaining qualified personnel, we will 
not be able to grow at the rate we desire, or at all. 

Risks Related to the Company’s Executive Officers and Board of Directors 

We  may  experience  difficulty  attracting  and  retaining  qualified  management  and  technical  personnel  to  grow  our 
business. 

We are dependent on the services of key executives and other highly skilled and experienced personnel to advance our 
corporate  objectives  as  well  as  the  identification  of  new  opportunities  for  growth  and  funding.  Mr. Giardini  and 
Ms. Sanders  are  currently  our  only  executive  officers.  It  will  be  necessary  for  us  to  recruit  additional  skilled  and 
experienced executives. Our inability to do so, or the loss of any of these persons or our inability to attract and retain 
suitable replacements for them, or additional highly skilled employees required for our activities, would have a material 
adverse effect on our business and financial condition. 

Some of our directors and officers have conflicts of interest as a result of their involvement with other natural resource 
companies. 

Certain of our directors and officers also serve as directors or officers, in other companies involved in natural resource 
exploration and development or mining-related activities, including, in particular, NovaGold. To the  extent  that such 
other  companies  may  participate  in  ventures  in  which  we  may  participate  in,  or  in  ventures  which  we  may  seek  to 
participate in, our directors and officers may have a conflict of interest in negotiating and concluding terms respecting 
the extent of such participation. In all cases where our directors and officers have an interest in other companies, such 

23 

other companies may also compete with us for the acquisition of mineral property investments. Any decision made by 
any of these directors and officers involving Trilogy will be made in accordance with their duties and obligations to deal 
fairly and in good faith with a view to the best interests of Trilogy and its shareholders. In addition, each of the directors 
is required to declare and refrain from voting on any matter in which these directors may have a conflict of interest in 
accordance with the procedures set forth in the Business Corporations Act (British Columbia) and other applicable laws. 
In appropriate cases, the Company will establish a special committee of independent  directors to review a  matter in 
which several directors, or management, may have a conflict. Nonetheless, as a result of these conflicts of interest, the 
Company may not have an opportunity to participate in certain transactions, which may have a material adverse effect 
on the Company’s business, financial condition, results of operation and prospects. 

In the future, we may be subject to legal proceedings. 

Due to the nature of our business, we may be subject to numerous regulatory investigations, claims, lawsuits and other 
proceedings  in  the  ordinary  course  of  our business.  The  results  of  these  legal  proceedings  cannot  be  predicted  with 
certainty due to the uncertainty inherent in litigation, including the effects of discovery of new evidence or advancement 
of new legal theories, the difficulty of predicting decisions of judges and juries and the possibility that decisions may be 
reversed  on  appeal.  There  can  be  no  assurances  that  these  matters  will  not  have  a  material  adverse  effect  on  our 
business. 

General Risk Factors 

General economic conditions may adversely affect our growth, future profitability and ability to finance. 

The unprecedented events in global financial markets in the past several years and the current impact of COVID-19 have 
had a profound impact on the global economy. Many industries, including the copper mining industry, are impacted by 
these market conditions. Some of the key impacts of the current financial market turmoil include contraction in credit 
markets resulting in a widening of credit risk, devaluations, high volatility in global equity, commodity, foreign exchange 
and precious metal markets and a lack of market liquidity. A worsening or slowdown in the financial markets or other 
economic conditions, including but not limited to, consumer spending, employment rates, business conditions, inflation, 
fuel and energy costs, consumer debt levels, lack of available credit, the state of the financial markets, interest rates and 
tax rates, may adversely affect our growth and ability to finance. Specifically: 

• 

• 

• 

• 

• 

the  volatility  of  copper,  zinc, lead  and  other  metal  prices would  impact  our  estimates of  mineral  resources, 
revenues, profits, losses and cash flow, and the feasibility of our projects; 

negative economic pressures could adversely impact demand for our future production, if any; 

construction related costs could increase and adversely affect the economics of any project; 

volatile energy, commodity and consumables prices and currency exchange rates could impact our estimated 
production costs; and 

the  devaluation  and  volatility  of  global  stock  markets  would  impact  the  valuation  of  our  equity  and  other 
securities. 

Future sales or issuances of equity securities could decrease the value of any existing Common Shares, dilute investors’ 
voting power and reduce our earnings per share. 

We may sell additional equity securities (including through the sale of securities convertible into Common Shares) and 
may  issue  additional  equity  securities  to  finance  our  operations,  exploration,  development,  acquisitions  or  other 
projects. We are authorized to issue an unlimited number of Common Shares. We cannot predict the size of future sales 
and issuances of equity securities or the effect, if any, that future sales and issuances of equity securities will have on 
the market price of the Common Shares. Sales or issuances of a substantial number of equity securities, or the perception 

24 

that such sales could occur, may adversely affect prevailing market prices for the Common Shares. With any additional 
sale or issuance of equity securities, investors will suffer dilution of their voting power and may experience dilution in 
our earnings per share. 

Our largest shareholder has significant influence on us and may also affect the market price and liquidity of the securities. 

Electrum Strategic Opportunities Fund L.P. (“Electrum”) is our single largest shareholder, controlling approximately 20% 
of the outstanding voting securities. Accordingly, Electrum will have significant influence in determining the outcome of 
any corporate transaction or other matter submitted to the shareholders for approval, including mergers, consolidations 
and the sale of all or substantially all of our assets and other significant corporate actions. Unless significant participation 
of other shareholders takes place in such shareholder meetings, Electrum may be able to approve such matters itself. 
The concentration of ownership of the shares by Electrum may: (i) delay or deter a change of control of the Company; 
(ii) deprive shareholders of an opportunity to receive a premium for their shares as part of a sale of the Company; and 
(iii) affect the market price and liquidity of the shares. Without the consent of Electrum, we could be prevented from 
entering into transactions that are otherwise beneficial to us. The interests of Electrum may differ from or be adverse to 
the interests of our other shareholders. The effect of these rights and Electrum’s influence may impact the price that 
investors are willing to pay for securities. If Electrum sells a substantial number of shares in the public market, the market 
price of the shares could fall. The perception among the public that these sales will occur  could also contribute to a 
decline in the market price of the shares. 

Our Common Shares are subject to various factors that have historically made share prices volatile. 

The market price of our Common Shares may be subject to large fluctuations, which may result in losses to investors. 
The  market  price  of  the  Common  Shares  may  increase  or  decrease  in  response  to  a  number  of  events  and  factors, 
including:  our  operating  performance  and  the  performance  of  competitors  and  other  similar  companies;  volatility  in 
metal prices; the arrival or departure of key personnel; the number of Common Shares to be publicly traded after an 
offering; the public’s reaction to our press releases, material change reports, other public announcements and our filings 
with  the  various  securities  regulatory  authorities;  changes  in  earnings  estimates  or  recommendations  by  research 
analysts who track the Common Shares or the shares of other companies in the resource sector; changes in general 
economic and/or political conditions; acquisitions, strategic alliances or joint ventures involving us or our competitors; 
and the factors listed under the heading “Cautionary Statement Regarding Forward-Looking Information.” 

The market price of the Common Shares may be affected by many other variables which are not directly related to our 
success and are, therefore, not within our control, including other developments that affect the market for all resource 
sector  securities,  the  breadth  of  the  public  market  for  the  Common  Shares  and  the  attractiveness  of  alternative 
investments. 

We do not intend to pay any cash dividends in the foreseeable future. 

We have not declared or paid any dividends on our Common Shares.  Our current business plan requires that for the 
foreseeable future, any future earnings be reinvested to finance the growth and development of our business.  We do 
not  intend  to  pay  cash  dividends  on  the  Common  Shares  in  the  foreseeable  future.  We  will  not  declare  or  pay  any 
dividends until such time as our cash flow exceeds our capital requirements and will depend upon, among other things, 
conditions  then  existing  including  earnings,  financial  condition,  restrictions  in  financing  arrangements,  business 
opportunities and conditions and other factors, or our Board determines that our shareholders could make better use 
of the cash. 

We may be a “passive foreign investment company” in future periods, which may have adverse U.S. federal income tax 
consequences for U.S. shareholders. 

U.S. investors in the Company should be aware that we believe  we were not  a  passive foreign  investment  company 
(“PFIC”) for the years ending November 30, 2015, 2016, 2017, 2020 and 2021 but we believe we were a PFIC for the 

25 

years ending November 30, 2018, 2019 and 2022 and may be a PFIC in future tax years. If we are a PFIC for any year 
during a U.S. Holder’s (as defined below under Certain U.S. Federal Income Tax Considerations – U.S. Holders”) holding 
period, then such U.S. Holder generally will be required to treat any gain realized upon a disposition of Common Shares 
and any so-called “excess distribution” received on its Common Shares as ordinary income, and to pay an interest charge 
on a portion of such gain or distributions, unless the shareholder makes a timely and effective “QEF Election” or a “Mark-
to-Market Election” (each as defined below under “Certain U.S. Federal Income Tax Considerations – Default PFIC Rules 
under Section 1291 of the Code”).  A U.S. Holder who makes a QEF Election generally must report on a current basis its 
share of our net capital gain and ordinary earnings for any year in which we are a PFIC, whether or not we distribute any 
amounts to our shareholders.  A U.S. Holder who makes the Mark-to-Market Election generally must include as ordinary 
income each year the excess of the fair market value of the Common Shares over the U.S. Holder’s tax basis therein.  This 
paragraph  is  qualified  in  its  entirety  by  the  discussion  below  the  heading  “Certain  U.S.  Federal  Income  Tax 
Considerations.” Each U.S. shareholder should consult its own tax advisor regarding the PFIC rules and the U.S. federal 
income tax consequences of the acquisition, ownership, and disposition of Common Shares.  

Global climate change is an international concern and could impact our ability to conduct future operations. 

Global climate change is an international issue and receives an enormous amount of publicity. We would expect that the 
imposition of international treaties or U.S. or Canadian federal, state, provincial or local laws or regulations pertaining 
to mandatory reductions in energy consumption or emissions of greenhouse gasses could affect the feasibility of our 
mining projects and increase our operating costs. 

Adverse publicity from non-governmental organizations could have a material adverse effect on us. 

There  is  an  increasing  level  of  public  concern  relating  to  the  effect  of  mining  production  on  our  surroundings, 
communities  and  environment.  Non-governmental  organizations  (“NGOs”),  some  of  which  oppose  resource 
development, are often vocal critics of the mining industry. While we seek to operate in a socially responsible manner, 
adverse publicity generated by such NGOs related to extractive industries, or our operations specifically, could have an 
adverse effect on our reputation and financial condition or our relationship with the communities in which we operate. 

We may fail to achieve and maintain the adequacy of our internal control over financial reporting as per the requirements 
of the Sarbanes-Oxley Act. 

We are required to document and test our internal control procedures in order to satisfy the requirements of Section 404 
of  SOX.  It  requires  an  annual  assessment  by  management  of  the  effectiveness  of  our  internal  control  over  financial 
reporting. We may in the future fail to achieve and maintain the adequacy of our internal control over financial reporting, 
as such standards are modified, supplemented or amended from time to time, and we may not be able to ensure that 
we can conclude on an ongoing basis that we have effective internal control over financial reporting in accordance with 
Section 404 of SOX. Our failure to satisfy the requirements of Section 404 of SOX on an ongoing, timely basis could result 
in the loss of investor confidence in the reliability of our financial statements, which in turn could harm our business and 
negatively  impact  the  trading  price  of  our  Common  Shares.  In  addition,  any  failure  to  implement  required  new  or 
improved controls, or difficulties encountered in their implementation, could harm our operating results or cause us to 
fail to meet our reporting obligations. Future acquisitions of companies may provide us with challenges in implementing 
the  required  processes,  procedures  and  controls  in  our  acquired  operations.  Acquired  companies  may  not  have 
disclosure control and procedures or internal control over financial reporting that are as thorough or effective as those 
required by securities laws currently applicable to us. 

Our business is subject to evolving corporate governance and public disclosure regulations that have increased both our 
compliance costs and the risk of noncompliance, which could have an adverse effect on our stock price. 

We are subject to changing rules and regulations promulgated by a number of United States and Canadian governmental 
and self-regulated organizations, including the SEC, the Canadian Securities Administrators, the NYSE American, the TSX, 
and the Financial Accounting Standards Board. These rules and regulations continue to evolve in scope and complexity 

26 

and many new requirements have been created in response to laws enacted by the United  States Congress, making 
compliance  more  difficult  and  uncertain.  Our  efforts  to  comply  with  new  rules and  regulations,  including  those 
promulgated  under  Dodd-Frank,  have  resulted  in,  and  are  likely  to  continue  to  result  in,  increased  general  and 
administrative  expenses  and  a  diversion  of  management  time  and  attention  from  revenue-generating  activities  to 
compliance activities. 

Item 1B.  UNRESOLVED STAFF COMMENTS 

None. 

Item 2.     PROPERTIES 

Trilogy’s  principal  business  is  the  exploration  and  development  of  the  Upper  Kobuk  Mineral  Projects  located  in  the 
Ambler mining district in Northwest Alaska, United States. The Upper Kobuk Mineral Projects are held by Ambler Metals 
LLC (“Ambler Metals”), a limited liability company owned equally by Trilogy and South32 Limited, and is comprised of 
the  (i)  Arctic  Project,  a  development  stage  property,  which  contains  a  high-grade  polymetallic  volcanogenic  massive 
sulfide deposit; and (ii) Bornite Project, an exploration stage property, which contains a carbonate-hosted copper - cobalt 
deposit. 

27 

 
 
 
 
Mineral Resource Summary Table as of November 30, 2022 

Project 

Resource 

Tonnage 

Average Grade 

Contained Metal Content 

Alaska 

Category 

(Mt) 

Cu 

(%) 

Pb 

(%) 

Zn 

Au 

Ag 

Cu 

Pb 

Zn 

Au 

Ag 

(%) 

(g/t) 

(g/t) 

(Mlb) 

(Mlb) 

(Mlb) 

(koz) 

(Moz) 

Arctic – 50% 
Attributable 
Interest 

Bornite – 
50% 
Attributable 
Interest 

Notes: 

Inferred 

2.25 

1.92 

0.70 

 2.93 

0.43 

35.6 

94.5 

34.5 

144 

31 

2.5 

Inferred 

101.3 

1.46 

3,257 

1.  Mineral Resources are current as of November 30, 2022 and were verified by a Wood QP. 
2.  Mineral Resources were prepared in accordance with the standards and definitions of S-K 1300 and represent first-time 

disclosure of Mineral Resources under S-K 1300 standards and definitions. 

3.  The Mineral Resource estimate is reported exclusive of those Mineral Resources that were converted to Mineral Reserves.  
4.  Trilogy Metals’ 50% attributable interest is stated in the table. 
5. 
6.  The mineral resources are reported in place (point of reference). 

Figures may not sum due to rounding. 

Arctic Notes: 

7.  Mineral Resources stated are contained within a conceptual pit shell developed using metal prices of $3.00/lb Cu, $0.90/lb 
Pb, $1.00/lb Zn, $1,300/oz Au and $18/oz Ag and metallurgical recoveries of 92% Cu, 77% Pb, 88% Zn, 63% Au and 56% Ag 
and operating costs of $3/t mining and $35/t process and general and administrative costs. The assumed average pit slope 
angle is 43º.  

8.  As a result of flattening the north end of the reserve pit to stabilize the pit wall due to the presence of talc, a portion of the 
reserve  pit  extended  beyond  the  resource  constraining  pit  shell  and  a  second  pass  of  mineral  resource  tabulation  was 
performed  exterior  to  the  constraining  resource  pit  and  interior  to  the  constraining  reserve  pit  which  is  included  in  the 
Mineral Resource tabulation. 

9.  The cut-off grade is 0.5% copper equivalent: CuEq = (Cu% x 0.92) + (Zn% x 0.290) + (Pb% x 0.231) + (Au g/t x 0.398) + (Ag g/t 

x 0.005). 

Bornite Notes: 

10.  Mineral resources are constrained by: an open pit shell at a cut-off grade of 0.5% Cu, with an average pit slope of 43 degrees; 
and underground mining shapes with a cut-off grade of 1.79% Cu.  The cut-off grades include the considerations of a $4.05/lb 
Cu price, process recovery of 87.2%, open pit mining costs of $3.21/t mined, underground mining cost of $73.62/t mined, 
process  cost  of  $19.14/t  processed,  G&A  cost  of  $4.14/t  processed,  treatment,  refining,  sales  cost  of  $0.73/lb  Cu  in 
concentrate, road use cost of $8.04/t processed, 2% NSR royalty.   

Mineral Reserve Estimate as of November 30, 2022 for the Arctic Project, Alaska USA 

Classification 

Probable Mineral Reserves – 50% 
Attributable Interest 

Notes: 

Tonnage 

 Average Grade 

Mt 

Cu (%) 

Pb (%) 

Zn (%) 

Au (g/t) 

Ag (g/t) 

23.35 

2.11 

0.56 

2.90 

0.42 

31.8 

1.  Mineral Reserves estimates are current as of November 30, 2022 and were prepared by a Wood QP. 

28 

 
 
 
 
 
 
 
 
 
2.  Mineral Reserves were estimated assuming open pit mining methods and include a combination of internal and contact 

dilution. Total dilution is expected to be between 30% and 40%. Pit slopes vary by sector and range from 26° to 56°. A 
marginal NSR cut-off of $38.8 /t is used. 

3.  Mineral Reserves are based on prices of $3.46/lb Cu, $0.91/lb Pb, $1.12/lb Zn, $1,615/oz Au, and $21.17/oz Ag. 
4.  Variable process recoveries averaging 92% Cu in Cu concentrate, 62% Pb in Pb concentrate, 88% Zn in Zn concentrate, 47% 

Au in Cu concentrate, 33% Ag in Cu concentrate, 26% Au in Pb concentrate and 49% Ag in Pb concentrate. 

5.  Mineral Reserves are based on mining cost of $2.52/t incremented at $0.02/t/5m and $0.012/t/5m below and above 790 

m elevation, respectively. 

6.  Costs applied to processed material following: process operating cost of $18.31/t, G&A of $5.83/t, sustaining capital cost 

7. 
8. 

of $2.37/t, closure cost of $4.27/t, road toll cost of $8.04/t.      
Strip ratio (waste:ore) is 7.3:1. 
Selling terms following: payables of 96.5% of Cu, 95% of Pb and 85% of Zn, treatment costs of $80/t Cu concentrate, 
$160/t Pb concentrate and $215/t Zn concentrate; refining costs of $0.08/lb Cu in Cu concentrate, and$10/oz Au, $1.25/oz 
Ag in Pb concentrate; and transport cost $270.98/t concentrate. 
Fixed royalty percentage of 1% NSR. 

9. 
10.  Trilogy Metals’ 50% attributable interest is stated in the table. 
11.  The point of reference for the Mineral Reserves is defined at the point where the ore is delivered to the processing plant. 
12.  The metal prices and costs were fixed over the 13-year mine life. 

The following descriptions summarize selected information about the Upper Kobuk Mineral Projects, which are located 
in the Ambler mining district of Alaska and include the Arctic Project and the Bornite Project. The Arctic Project and the 
Bornite  Project  are  held  by  Ambler  Metals,  of  which  Trilogy  holds  a  50%  interest.  All  mineral  resources  and  mineral 
reserve estimates with respect to the Arctic Project and Bornite Project that are disclosed in this Annual Report on Form 
10-K are reported on a 100% basis unless otherwise noted. Please also see “Management’s Discussion and Analysis—
Project  Activities”  for  more  information  on  the development  and nature  of  our  interest  in  the  Upper  Kobuk  Mineral 
Projects. 

The Company’s book value of its investment in the Upper Kobuk Mineral Projects is $142.8 million as of November 30, 
2022. 

Arctic Project 

The Company is subject to and required to disclose mineral resources and mineral reserves in accordance with Subpart 
229.1300 of Regulation S-K – Disclosure by Registrants Engaged in Mining Operations (“S-K 1300”). While the S-K 1300 
rules are similar to National Instrument 43-101 Standards of Disclosure for Mineral Projects (“NI 43-101”) rules in Canada, 
they are not identical and therefore two reports have been produced for the Arctic Project. The information in Item 2, 
Properties, contains pertinent information required under both NI 43-101 and S-K 1300. 

Except as otherwise stated, the scientific and technical information relating to the Arctic Project contained in this Form 
10-K is derived  from the (i) 2023 S-K  1300 report  for Arctic titled “Arctic Project  Technical Report  Summary, Ambler 
Mining District, Alaska” dated November 30, 2022 prepared by Ausenco Engineering Canada Inc., Wood Canada Limited,  
SRK Consulting (Canada) Inc. and Brown and Caldwell, each of whom are not affiliated with Trilogy  (“S-K 1300 Arctic 
Report”) and the (ii) 2023 Arctic Report titled “Arctic Project NI 43-101 Technical Report on Feasibility Study, Ambler 
Mining District, Alaska” with an effective date of January 20, 2023, prepared by Ausenco Engineering Canada Inc., Wood 
Canada  Limited,  SRK  Consulting  (Canada)  Inc.  and  Brown  and  Caldwell  (“NI  43-101  Arctic  Report”).    The  information 
regarding the Arctic Project is based on assumptions, qualifications and procedures which are not fully described herein.  
Reference should be made to the full text of the S-K 1300 Arctic Report and the NI 43-101 Arctic Report which has been 
filed, as applicable, with the relevant US and Canadian securities regulatory authorities.  The NI 43-101 Arctic Report is 
available for review on SEDAR at www.sedar.com and the S-K 1300 Arctic Report is available for review on EDGAR at 
www.sec.gov.  

29 

 
Arctic Project Description, Location and Access 

Project Description 

NovaGold acquired the Arctic Project from Kennecott Exploration Company and Kennecott Arctic Company (collectively, 
“Kennecott”) in 2004. In 2011, NovaGold transferred all copper projects to NovaCopper Inc. and spun-out NovaCopper 
to its then existing shareholders in 2012. NovaCopper Inc. subsequently underwent a name change to Trilogy Metals Inc. 
in 2016. Under the Kennecott Purchase and Termination Agreement, Kennecott retained a 1% net smelter return (“NSR”) 
royalty that was subsequently sold by Kennecott. The 1% NSR runs with the lands and is purchasable at any time from 
the royalty holder for a one-time payment of $10 million. 

The Arctic Project  is directly held by Ambler Metals LLC (“Amber Metals”), in a  50/50 joint  venture formed between 
South32 and Trilogy in February 2020. Upon the formation of the joint venture, Trilogy contributed all of its Alaskan 
assets,  including  the  Arctic  Project  and  the  NANA  Agreement,  to  Ambler  Metals  in  exchange  for  a  50%  membership 
interest and at the same time, South32 contributed $145 million in cash for a 50% membership interest. 

The  land  tenure  consists  of  2,136  contiguous  State  claims  totaling  230,736  acres  (93,336  ha),  including  905  40-acre 
claims, 1231 160-acre claims, and 18 Federal patented claims comprising 271.9 acres (110 ha) held in the name of Ambler 
Metals. Surface use of the private land held as Federal patented claims is limited only by reservations in the patents and 
by generally-applicable environmental laws. Surface use of State claims allows the owner of the mining claim to make 
such use of the surface as is “necessary for prospecting for, extraction of, or basic processing of minerals.” 

NANA controls lands granted under the Alaska Native Claims Settlement Act to the south of the Arctic Project boundary. 
Ambler  Metals  and  NANA  are  parties  to  the  NANA  Agreement  that  consolidates  the  parties’  land  holdings  into  an 
approximately 190,929 ha land package and provides a framework for the exploration and development of the area. The 
NANA Agreement has a term of 20 years, with an option in favour of Ambler Metals to extend the term for an additional 
10 years. If, following receipt of a feasibility study and the release for public comment of a related draft environmental 
impact  statement,  a  decision  is  made  to  proceed  with  construction  of  a  mine  on  the  lands  subject  to  the  NANA 
Agreement, NANA will have 120 days to elect to either (a) exercise a non-transferrable back-in-right to acquire between 
16% and 25% (as specified by NANA) of that specific project; or (b) not exercise its back-in-right, and instead receive a 
net  proceeds royalty equal to 15% of the net  proceeds realized from such project. In the event  that NANA elects to 
exercise its back-in-right, the parties will, as soon as reasonably practicable, form a joint venture with NANA electing to 
participate between 16% to 25%, and Ambler Metals owning the balance of the interest in the joint venture. If Ambler 
Metals decides to proceed with construction of a mine on its own lands subject to the NANA Agreement, NANA will enter 
into a  surface use agreement which  will afford Ambler Metals access to the Arctic Project  along routes approved by 
NANA. In consideration for the grant of such surface use rights, NANA will receive a 1% net smelter royalty on production 
and provide an annual payment on a per acre basis. 

Location and Access 

The Arctic Project is located in the Ambler mining district of the southern Brooks Range, in the Northwest Arctic Borough 
(“NWAB”)  of  Alaska.  The  Arctic  Project  is  geographically  isolated  with  no  current  road  access  or  nearby  power 
infrastructure. The Arctic Project is about 270 km east of the town of Kotzebue, 37 km northeast of the village of Kobuk, 
and 260 km west of the Dalton Highway, an all-weather State maintained public road, at geographic coordinates N67.17° 
latitude and W156.39° longitude and Universal Transverse Mercator (UTM) North American Datum (NAD) 83, Zone 4 
coordinates 7453080N, 613110E. 

30 

 
 
Primary  access  to  the  Arctic  Project  is  by  air,  using  both  fixed  wing  aircraft  and  helicopters.  There  are  four  well-
maintained,  approximately  1,500  m-long  gravel  airstrips  located  near  the  Arctic  Project,  capable  of  accommodating 
charter  fixed  wing  aircraft.  These  airstrips  are  located  64  km  west  at  Ambler,  46  km  southwest  at  Shungnak,  37  km 
southwest at Kobuk, and 34 km southwest at Dahl Creek. There is daily commercial air service from Kotzebue to the 
village of Kobuk, the closest community to the Arctic Project. During the summer months, the Dahl Creek Camp airstrip 
is suitable for larger aircraft, such as a C-130 and DC-6. 

In addition to the four 1,500 m airstrips, there is a 700 m airstrip located at the Bornite Camp. The airstrip at Bornite is 
suited to smaller aircraft, which support the Bornite Camp with personnel and supplies. There is also a 450 m airstrip 
(Arctic airstrip) located at the base of Arctic Ridge that can support smaller aircraft. 

A winter trail and a one-lane dirt track suitable for high-clearance vehicles or construction equipment links the Arctic 
Project’s main camp located at Bornite to the Dahl Creek airstrip southwest of the Arctic deposit. An unimproved gravel 
track connects the Arctic airstrip with the Arctic deposit. 

History 

Prospectors in search of gold, travelling up the Kobuk River in 1898-99 (Grinnell, 1901), found small gold placer deposits 
in the southern Cosmos Hills, south of the Arctic deposit, which were worked intermittently over the ensuing decades. 
Around this time, copper mineralization at Ruby Creek and Pardner Hill in the northern Cosmos Hills was explored using 
small  shafts  and  adits  (Smith  and  Eakin,  1911).  In  1947,  Rhinehart  “Rhiny”  Berg  staked  claims  over  the  Ruby  Creek 
prospects,  carried  out  extensive  trenching  and  the  first  diamond  drilling,  and  constructed  an  airstrip  for  access 
(alaskamininghalloffame.org 2012). 

Bear Creek Mining Company (“BCMC”), an exploration subsidiary of Kennecott, optioned the Ruby Creek property from 
Berg in 1957.  The prospect became known as Bornite and Kennecott  conducted extensive exploration over the next 
decade, culminating in the discovery of the high-grade No. 1 zone and the sinking of an exploration shaft to conduct 
underground drilling. 

While  exploring  the  Bornite  deposit,  BCMC  carried  out  reconnaissance  exploration  throughout  the  western  Brooks 
Range,  including  a  large  regional  stream  sediment  survey  in  1962.  Initial  follow  up  did  not  identify  mineralization  of 
interest  however  in  1965,  Riz  Bigelow  (BCMC)  and  his  team  of  geologists  found boulders  of  massive  sulphides  at  an 
anomaly (1400 ppm Cu) located 28 km northeast of Bornite that led to the discovery of outcropping mineralization the 
following year. The area was subsequently staked and, in 1967, nine core holes were drilled at the Arctic deposit, eight 
of which yielded massive sulphide intercepts over an almost 500-m strike length. 

31 

 
BCMC conducted intensive exploration on the property until 1977 and then intermittently through to 1998. No drilling 
or additional exploration was conducted on the Arctic Project between 1999 and 2003. 

In  addition  to  drilling  and  exploration  at  the  Arctic  deposit,  BCMC  also  conducted  exploration  at  numerous  other 
prospects in the Ambler Mining District (most notably Dead Creek, Sunshine, Cliff, and Horse). The abundance of VMS 
prospects in the district resulted in a series of competing companies in the area, including Sunshine Mining Company, 
Anaconda  Company,  Noranda  Exploration  Company,  GCO  Minerals  Company,  Cominco  American  Resource  Inc. 
(Cominco), Teck Cominco, Resource Associates of Alaska, Watts, Griffis and McOuat Ltd., and Houston Oil and Minerals 
Company, culminating into a claim staking war in the district in 1973. Falconbridge and Union Carbide also conducted 
work later in the district. 

District exploration by Sunshine Mining Company and Anaconda resulted in two additional significant discoveries in the 
district; the Sun deposit located 60 km east of the Arctic deposit, and the Smucker deposit located 36 km west of the 
Arctic deposit. These two deposits are outside the current Arctic Project area. 

District exploration continued until the early 1980s on the four larger deposits in the district (Arctic, Bornite, Smucker 
and Sun) when the district fell into a hiatus due to depressed metal prices. 

In 1987, Cominco acquired the claims covering the Sun and Smucker deposits from Anaconda. Teck Resources Limited, 
as  Cominco’s  successor  company,  continues  to  hold  the  Smucker  deposit.  In  2007,  Andover  Mining  Corporation 
purchased a 100% interest in the Sun deposit for $13 million and explored the property through 2013. The Sun deposit 
and adjacent lands were acquired by Valhalla Metals Inc., a private company, which staked over the Sun deposit in 2017 
after the creditors for the bankrupt Andover Mining Corporation failed to pay the annual rent of the state claims and 
submit the Annual Labour Statement. 

In  1981  and  1983,  Kennecott  received  three  US  Mineral  Survey  patents  (MS2245  totaling  240  acres  over  the  Arctic 
deposit – later amended to include another 32 acres; and MS2233 and MS2234 for 25 claims totaling 516.5 acres at 
Bornite). The Bornite patented claims and surface development were subsequently sold to NANA Regional Corporation, 
Inc. in 1986. 

No production has occurred at the Arctic deposit or at any of the other deposits within the Ambler Mining District.  

Prior Ownership and Ownership Changes – Arctic Deposit and the Ambler Lands 

BCMC initially staked federal mining claims covering the Arctic deposit area beginning in 1966. The 1960’s drill programs 
defined a significant high-grade polymetallic resource at the Arctic deposit and, in the early 1970s, Kennecott began the 
patent process to obtain complete legal title to the Arctic deposit. In 1981, Kennecott received US Mineral Survey patent 
M2245 covering 16 mining claims totaling 240.018 acres. In 1983, US Mineral Survey patent M2245 was amended to 
include two additional claims totaling 31.91 acres. 

With the passage of the Alaska National Interest Lands Conservation Act in 1980, which expedited native land claims 
outlined in the ANSCA and State lands claims under the Alaska Statehood Act, both the State of Alaska and NANA selected 
significant areas of land within the Ambler Mining District. State selections covered much of the Ambler schist belt, host 
to the volcanogenic massive sulphide deposits including the Arctic deposit, while NANA selected significant portions of 
the Ambler Lowlands to the immediate south of the Arctic deposit as well as much of the Cosmos Hills including the area 
immediately around Bornite. 

In 1995, Kennecott renewed exploration in the Ambler schist belt containing the Arctic deposit patented claims by staking 
an additional 48 state claims at Nora and 15 state claims at Sunshine Creek. In the fall of 1997, Kennecott staked 2,035 
state claims in the belt consolidating their entire land position and acquiring the majority of the remaining prospective 
terrain in the VMS belt. Five more claims were subsequently added in 1998. After a short period of exploration which 
focused on geophysics and geochemistry combined with limited drilling, exploration work on the Arctic Project again 
entered a hiatus. 

32 

On  March  22,  2004,  Alaska  Gold  Company  (“Alaska  Gold”),  a  wholly-owned  subsidiary  of  NovaGold  completed  an 
Exploration and Option Agreement with Kennecott to earn an interest in the Ambler land holdings. 

Previous Exploration and Development Results – Arctic Deposit 

Kennecott’s ownership of the Arctic Project saw two periods of intensive work from 1965 to 1985 and from 1993 to 1998, 
before optioning the property to NovaGold in 2004. 

Though reports, memos, and files exist in Kennecott’s Salt Lake City office, only limited digital compilation of the data 
exists  for  the  earliest  generation  of  exploration  at  the  Arctic  deposit  and  within  the  VMS  belt.  Beginning  in  1993, 
Kennecott initiated a re-evaluation of the Arctic deposit and assembled a computer database of previous work at the 
Arctic deposit and in the district. A computer-generated block model was constructed in 1995 and an updated resource 
estimate was performed using the block model. Subsequently, Kennecott staked a total of 2,035 State of Alaska claims 
in 1997 and, in 1998 undertook the first field program since 1985. 

Due to the number of companies and the patchwork exploration that occurred as a result of the 1973 staking war, much 
of the earliest exploration work on the Ambler Schist belt was lost during the post-1980 hiatus in district exploration. 
The following subsections outline the best documented data at the Arctic deposit as summarized in the 1998 Kennecott 
exploration report, including the assembled computer database; however, this outline is not considered to be either 
exhaustive or in-depth. 

In 1982, geologists with Kennecott, Anaconda and the State of Alaska published the definitive geologic map of the Ambler 
schist belt (Hitzman et al. 1982). 

The  S-K  1300  Arctic  Report  and  the  NI  43-101  Arctic  Report  both  summarize  the  known  exploration  mapping, 
geochemical,  and  geophysical  programs  conducted  for  VMS  targets  in  the  Ambler  Mining  District.    Table  1  below 
summarizes the exploration mapping, geochemical, geophysical, and mining studies conducted on the Arctic deposit.  

Geological Setting, Mineralization and Deposit Types  

Regional Geology – Southern Brooks Range 

The Ambler Mining District occurs along the southern margin of the Brooks Range within an east-west trending zone of 
Devonian to Jurassic age submarine volcanic and sedimentary rocks (Hitzman et al., 1986). The district covers both: 1) 
VMS-like deposits and prospects hosted in the Devonian age Ambler Sequence (or Ambler Schist belt or Schist Belt), a 
group of metamorphosed bimodal volcanic rocks with interbedded tuffaceous, graphitic and calcareous volcaniclastic 
metasediments; and 2) epigenetic carbonate-hosted copper deposits occurring in Silurian to Devonian age carbonate 
and  phyllitic  rocks  of  the  Bornite  Carbonate  Sequence.  The  Ambler  Sequence  occurs  in  the  upper  part  of  the  Anirak 
Schist,  the  thickest  member  of  the  Schist  belt  or  Coldfoot  subterrane  (Moore  et  al.,  1994).  VMS-like  stratabound 
mineralization can be found along the entire 110 km strike length of the district. Immediately south of the Schist belt, in 
the  Cosmos  Hills,  a  time  equivalent  section  of  the  Anirak  Schist  that  includes  the  approximately  1  km  thick  Bornite 
Carbonate Sequence. Mineralization of both the VMS-like deposits of the Schist belt and the carbonate-hosted deposits 
of the Cosmos Hills has been dated at 375 to 387 Ma (Selby et al., 2009; McClelland et al., 2006). 

The Ambler Mining District is characterized by increasing metamorphic grade to the north, perpendicular to the strike of 
the east-west  trending units. The district  shows isoclinal folding in the northern portion and thrust  faulting to south 
(Schmidt, 1983). The Devonian to Late Jurassic age Angayucham basalt and the Triassic to Jurassic age mafic volcanic 
rocks are in low-angle over thrust contact with various units of the Ambler Schist belt and Bornite Carbonate Sequence 
along the northern edge of the Ambler Lowlands. 

33 

 
 
Ambler Sequence Geology 

Rocks that form the Ambler Sequence consist of a lithologically diverse sequence of lower Devonian age carbonate and 
siliciclastic strata with interlayered mafic lava flows and sills. The clastic strata, derived from terrigenous continental and 
volcanic sources, were deposited primarily by mass-gravity flow into the sub-wavebase environment of an extending 
marginal basin. 

The Ambler Sequence underwent two periods of intense, penetrative deformation. Sustained upper greenschist-facies 
metamorphism with coincident formation of a penetrative schistosity and isoclinal transposition of bedding marks the 
first  deformation  period.  Pervasive  similar-style  folds  on  all  scales  deform  the  transposed  bedding  and  schistosity, 
defining the subsequent event. At least two later non-penetrative compressional events deform these earlier fabrics. 
Observations  of  the  structural  and  metamorphic  history  of  the  Ambler  Mining  District  are  consistent  with  current 
tectonic  evolution  models  for  the  Schist  belt,  based  on  the  work  of  others  elsewhere  in  the  southern  Brooks  Range 
(Gottschalk and Oldow, 1988; Till et al., 1988; Vogl et al., 2002). 

Arctic Deposit Geology 

Previous workers at the Arctic deposit (Russell 1995 and Schmidt 1983) describe three mineralized horizons: the Main 
Sulphide  Horizon,  the  Upper  South  Horizon  and  the  Warm  Springs  Horizon.  The  Main  Sulphide  Horizon  was  further 
subdivided into three zones: the southeast zone, the central zone and the northwest zone. Previous deposit modelling 
was grade-based resulting in numerous individual mineralized zones representing relatively thin sulphide horizons. 

Recent work by Ambler Metals defines the Arctic deposit as two or more discrete horizons of sulphide mineralization 
contained in a complexly deformed isoclinal fold with an upright upper limb and an overturned lower limb hosting the 
main mineralization. Nearby drilling suggests that a third upright lower limb, likely occurs beneath the currently explored 
stratigraphy. 

Mineralization   

Mineralization  occurs  as  stratiform  semi-massive  sulphide  (“SMS”)  to  massive  sulphide  (“MS”)  beds  within  primarily 
graphitic schists and fine-grained quartz mica schists. The sulfide beds average 4 m in thickness but vary from less than 
1 m up to as much as 18 m in thickness. The sulfide mineralization occurs within eight modelled zones lying along the 
upper  and  lower  limbs  of  the  Arctic  isoclinal  anticline.  The  zones  are  all  within  an  area  of  roughly  1  km2  with 
mineralization extending to a depth of approximately 250 m below the surface. There are five zones of MS and SMS that 
occur at specific pseudo-stratigraphic levels which make up the bulk of the Mineral Resource estimate. The other three 
zones also occur at specific pseudo-stratigraphic levels, but are too discontinuous. 

Unlike more typical VMS deposits, mineralization is not characterized by steep metal zonation or massive pyritic zones. 
Mineralization  dominantly  consists  of  sheet-like  zones  of  base  metal  sulfides  with  variable  pyrite  and  only  minor 
zonation, usually on a small scale. 

Mineralization  is  predominately  coarse-grained  sulphides  comprising  chalcopyrite,  sphalerite,  galena,  tetrahedrite-
tennantite,  pyrite,  arsenopyrite,  and  pyrrhotite.  Sulphides  occur  as  disseminated  (<30%),  semi-massive  (30  to  50% 
sulphide) to massive (greater than 50% sulphide) layers. Trace amounts of electrum are also present. Gangue minerals 
associated  with  the  mineralized  horizons  include  quartz,  barite,  white  mica,  chlorite,  stilpnomelane,  talc,  calcite, 
dolomite and cymrite. 

Deposit Types 

The mineralization at the Arctic deposit and at several other known occurrences within the Ambler Sequence stratigraphy 
of the Ambler Mining District consists of Devonian age, polymetallic (zinc-copper-lead-silver-gold) VMS-like occurrences. 

34 

Observations and interpretations at the Arctic deposit such as: 1) the tectonic setting with Devonian volcanism in an 
evolving continental rift; 2) the geologic setting with bimodal volcanic rocks including pillow basalts and felsic volcanic 
tuffs; 3) an alteration assemblage with well-defined magnesium-rich footwall alteration and sodium-rich hanging wall 
alteration; and 4) typical polymetallic base-metal mineralization with massive and semi-massive sulphides, are indicative 
of a VMS deposit that has undergone high strain and complex folding and faulting.   

A variety of VMS types have been well documented in the literature (Franklin et al., 2005), with the Ambler Schist belt 
deposits most like deposits associated with bimodal felsic dominant volcanism related to incipient rifting. However, the 
abundance  of  volcaniclastic  rocks  with  argillaceous  sedimentary  rocks  and  the  tabular  nature  of  mineralization  are 
considered by Piercey (2022) to be similar to felsic silicilastic VMS environments. 

Evidence  exists  for  both  exhalation  and  emplacement  on  the  seafloor  and  replacement  of  rocks  in  the sub-seafloor, 
either via filling of void space or via dissolution of original rocks and replacement by new minerals (Piercey, 2022). For 
example, the presence of barite, attributed to the mixing of BaCl2(aq) from hydrothermal fluids with seawater sulphate 
(SO4(aq)) at the vent-seawater interface supports some of the mineralization at Arctic likely precipitated on the seafloor. 
In contrast, there is ample textural evidence of subseafloor replacement at Arctic, such as the presence of transitions 
from massive sulphides into selective replacement of interpreted permeable tuff beds in the hanging wall mudstones. 

The tonnage, grades, and stratigraphic setting of the Arctic deposit, and its broader tectonostratigraphic setting, are 
similar to other felsic siliclastic VMS environments globally. The deposit has strong similarities to deposits found the 
Finlayson Lake VMS district, Yukon, Bathurst district, New Brunswick, and some parts of the Iberian Pyrite Belt, Spain-
Portugal (Piercey, 2022). 

A VMS model is considered applicable for use in exploration targeting in the Arctic Project area.  

Exploration 

Table 1 summarizes the exploration work conducted by NovaGold, Trilogy (formerly, NovaCopper) and Ambler Metals 
from  2004  to  the  present.  Field  exploration  was  largely  conducted  during  the  period  between  2004  to  2007  with 
associated engineering and characterization studies between 2008 and 2019. 

Table 1 - Summary of Overall Exploration Activities Targeting VMS Style Mineralization in the Ambler Sequence 
Stratigraphy and the Arctic Deposit 

Work Completed 

Year 

Details 

Focus 

Geological Mapping 

- 

- 

- 

- 

- 

- 

2004 

2005 

2006 

2015, 2016 

2016 

2021 

- 

- 

- 

SRK 

- 

- 

35 

Arctic deposit surface 
geology 
Ambler Sequence west of 
the Arctic deposit 
COU, Dead Creek, 
Sunshine, Red 
Geotechnical Structural 
Mapping 
Arctic deposit surface 
geology 
Snow, Ambler, Nani, DH, 
Cliff, Sunshine, Dead 
Creek, BT, 98-9/Pipe, 
COU, SE Arctic, Nora 

 
Work Completed 

Year 

Details 

- 

2022 

- 

Geophysical Surveys 

SWIR Spectrometry 

TDEM 

Downhole EM 
VTEM Plus (Versatile Time 
Domain Electromagnetic) 
airborne helicopter 
geophysical 

ZTEM (Z-Axis Tipper 
Electromagnetic) airborne 
helicopter geophysical 

Geochemistry 

- 

- 

- 

- 

- 

- 

- 

2004 

2005 

2006 

2007 

2007 

2019 

2019 

2005 

2006 

2007 

2021 

2022 

2004 drill holes 

2 loops 

13 loops 

6 loops 

4 drill holes 

400m line spacing with 200m infill with tie 
lines 4000m spacing 

400m line spacing with tie lines 4000m 
spacing 

- 

- 

- 

- 

- 

- 

Focus 
Snow, Ambler, Nani, DH, 
Bud, Sunshine, Dead 
Creek, BT, 98-9/Pipe, 
COU, East Arctic, Nora, 
South Cliff, SK, Cynbad, Z, 
Tom Tom, Kogo/White 
Creek 

Alteration 
characterization 
Follow-up of Kennecott 
DIGHEM EM survey 
District targets 

Arctic extensions 

Arctic deposit 
Ambler Mining District 
and Cosmos Hills with 
infill over Arctic, Sunshine 
and Horse-Cliff 
Ambler Mining District 
and Cosmos Hills with 
infill over Arctic, Sunshine 
and Horse-Cliff 

Stream silts – core area 
prospects 
Soils – core area prospects 
Stream silts – core area 
prospects 
Soils – Arctic deposit area 
Soils - VTEM 26-29, JA 
Creek, West Dead Creek, 
Dead Creek 
Soils - Sub Arctic Valley, 
South Cliff, VTEM 26-29, 
VTEM-41, VTEM-23 , East 
and West Sunshine, Tom 
Tom, Kogo/White Creek, 
SK, Cynbad, East Arctic,  
West Dead Creek, Dead 
Creek, 98-9/Pipe, Z, Nora, 
Ambler, Nani 
Streams silts - Core area 
prospects 

Survey 

Collar 

2004 to 
2011, 

DGPS 

All 2004 to 2019 
NovaCopper drill holes 

36 

  
Work Completed 

Year 
2018, 
2019, 
2021, 2022 

2004, 2008 

Photography/Topography 

2010 

LiDAR Survey 

2015, 2016 

Technical Studies 

Geotechnical 

ML/ARD 

Metallurgy 

2010 

2011 

2012 

Geotechnical and Hydrology 

2012 

Geotechnical and Hydrology 

ML/ARD 

Metallurgy 

Project Evaluation 

Resource Estimation 

PEA 

PFS 

FS 

2015, 
2016, 
2018, 
2019, 
2021, 2022 
2015, 
2016, 
2017, 
2018, 2019 

2015, 
2016, 
2017, 
2018, 
2019, 2021 

2008 

2011 

2012 

2018 

2020 

Details 

Focus 

Resurveys 

- 

- 

BGC 

SRK 

SGS 

BGC 

SRK 

SRK 

SGS, ALS 

SRK 

SRK 

Tetra Tech 

Ausenco 

Ausenco 

Historical Kennecott drill 
holes 

Photography/topography 

LiDAR over Arctic Deposit 

Preliminary geotechnical 
and hazards 
Preliminary ML and ARD 
Preliminary mineralogy 
and metallurgy 
Preliminary rock 
mechanics and hydrology 

Arctic P                                                                                                                               
FS and FS slope design 

Static kinetic tests and 
ABA update - ongoing 

Cu-Pb Separation 
Testwork; Flotation and 
Variability Testwork; SAG 
Mill Comminution (SMC) 
Testwork, filtration 
Testwork, thickener 
Testwork, and tailings 
settling testing 

Resource estimation 

PEA - Underground 

PEA – Open Pit 

Pre-Feasibility Study 

Feasibility Study 

SWIR = short wave infrared; LiDAR = light detection and ranging; ML = metal leaching; BGC = BGC Engineering 

Note: 
Inc.; SGS = SGS Canada; ALS = ALS Metallurgy; PEA = preliminary economic assessment. 

Drilling  

Drilling  at  the  Arctic  deposit  and  within  the  Ambler  Mining  District  has  been  ongoing  since  the  initial  discovery  of 
mineralization  in  1966.  Approximately  67,639  m  of  drilling  has  been  completed  within  the  Ambler  Mining  District, 

37 

  
including 55,038 m of drilling in 285 drill holes at the Arctic deposit or on potential extensions in 32 campaigns spanning 
56 years.  

All drill holes, except 11 geotechnical holes in 2017, 24 geotechnical holes drilled in 2018, 8 holes from the 2021 program 
and 34 holes from the 2022 program, for which assay results were not available - were considered for use in the estimate 
of Mineral Resources. 

Geotechnical drilling is summarized in Table 2 and Table 3. The number of holes reported for each year are the holes 
that were staffed by a geotechnician at the rig and primary purpose was to gather geotechnical data. 

Table 2 – Summary of Geotechnical Drilling 

Number of Holes 
Oriented core 

Water level monitoring  

Falling head packer tests 

Point load tests 

Uniaxial compressive strength 

Direct shear testing 
Modulus testing 
Triaxial testing 
Acoustic Televiewer 
Falling Head, Singleor Straddle packer 
tests 
Airlift pump test 

Hydraulic conductivity testing (slug 
testing) 

Cohesive and residual shear strength 
tests on soils 

Compressive strength test on core and 
rock  

Extended duration injection tests 

2011 
5 
X 

2015 
2 
X 

2016 
3 
X 

2017 
11 

2018 
24 

2019 
4 
X 

2021 
8 
X 

2022 
5 
X 

X 

X 

X 

X 
X 
X 

X 

X 

X 

X 

X 

X 

X 

X 
X 
X 
X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 
X 
X 

X 

38 

 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 3 – Summary of Geotechnical Drilling by Year and Purposes 

Year 

2011 

2015 

2016 

2017 

2018 

2019 

2021 

2022 

Purpose 
Obtain geotechnical data in areas of the deposit that may host underground infrastructure 
or could pose issues with underground mining. 
Collect geotechnical and hydrological data to better understand the wall rock 
characteristics and hydrology within the open pit area. 
Complete the 3 drill holes that were deferred/not completed from the 2015 program. 
Collect geotechnical and hydrological data for tailings management and waste rock 
facilities within the entire Sub Arctic Creek valley. 
Collect geotechnical and hydrological data for waste rock dump, tailings management 
facility, and surface infrastructure in the Upper Sub Arctic Creek Valley. 
Provide additional geotechnical and hydrological data for pit design for the Feasibility 
Study.  
Define talc horizons on east side of pit for pit design. 

Define extent of lower talc horizons on northeast side of pit for pit design. 

NovaGold re-surveyed collars of selected historical holes in 2004 and again in 2008. The re-surveys showed little variation 
compared to the historical surveys. The downhole survey data show a pronounced deviation of the drill holes toward an 
orientation more normal to the foliation. 

Incomplete Kennecott data exist with regards to overall core recovery but based on 917 intervals of 3.05 m or less in the 
historical database, the average recovery was 92%. Kennecott RQD measurements in the 1998 program averaged 87.0%. 
There has been no systematic evaluation of recovery by rock type. 

Core recovery during NovaGold/NovaCopper/Trilogy Metals and Ambler Metals drill programs were good to excellent, 
resulting in quality samples with little to no bias. 

Sampling, Analysis and Data Verification 

Sampling and Analysis 

The  data  for  the  Arctic  deposit  were  generated  over  three  primary  drilling  campaigns:  1966  to  1986  when  BCMC,  a 
subsidiary of Kennecott was the primary operator, 1998 when Kennecott resumed work after a long hiatus, and 2004 to 
present under NovaGold, Trilogy (formerly, NovaCopper), and Ambler Metals. 

Between 2004 and 2005, NovaGold conducted a systematic drill core re-logging and re-sampling campaign of Kennecott 
and BCMC era drill holes AR-09 to AR-74. NovaGold either took 1 to 2 m samples every 10 m or sampled entire lengths 
of previously unsampled core within a minimum of 1 m and a maximum or 3 m intervals. The objective of the sampling 
was to generate a full ICP geochemistry dataset for the Arctic deposit and ensure continuous sampling throughout the 
deposit. 

From 2004 to 2019, sample intervals are determined by the geological relationships observed in the core and limited to 
a  2.5  m  maximum  length  and  1  m  minimum  length.  Sample  intervals  terminate  at  lithological  and  mineralization 
boundaries.  

After logging, the core was cut in half using diamond core saws. If core was not competent, it was split by using a spoon 
to transfer half of the core into the sample bag. One-half of the core was returned to the core box for storage on site 
and the other half was bagged, labelled, and sent to ALS Minerals Laboratories in Vancouver for analysis, via the (ALS 
preparation facility in Fairbanks Alaska) and the other half was archived in the core storage facility at the Bornite Camp 

39 

 
 
 
facilities or at the  Ambler Metals warehouse in  Fairbanks. For  the  2021 metallurgical  holes, ¼  core  was sampled  for 
analysis at ALS, ¼ retained, and ½ sent for metallurgical testing. 

Samples were logged into a tracking system on arrival at ALS Minerals, and weighed. Samples were then crushed dried, 
and a 250 g split pulverized to greater than 85% passing 75 μm. 

Samples  were  submitted  for multielement  analysis  of  a  0.25  gram  sample  by  Inductively  Coupled  Plasma  (ICP)  Mass 
Spectrometry (MS) following a 4-acid digestion, and for gold analysis of a 30 gram sample by Fire Assay (FA) with an 
Atomic Absorption (AA) finish.  Over limit ICP-MS Cu, Pb, and Zn samples were resubmitted for analysis of a 0.4 gram 
sample by ICP-Atomic Emission Spectroscopy (AES) or AA following a 4 acid digestion. The overlimit value for Cu, Pb, and 
Zn is 10,000 ppm. Over limit gold results were resubmitted for analysis of a 30 gram sample by FA with a Gravimetric 
finish. The overlimit value for Au is 10 ppm. The Lower detection limits for Cu, Pb, and Zn by ICP-MS are 0.2 ppm, 0.5 
ppm, and 2 ppm respectively. The lower detection limit for Au by FAAA is 0.05 ppm.  

Between 2004 and 2005 NovaGold completed a resampling program of historic drill holes. As a result, 85% of the assay 
intervals now have recent assay results from ALS Minerals.  

All core and pulp reject samples submitted to the ALS Minerals laboratory since 2004 were accompanied by standard, 
blank and duplicate control samples. Secondary laboratory check samples were analysed at Acme in Vancouver or SGS 
Burnaby.  The  secondary  laboratory  check  samples  were  selected  to  represent  the  data  population  using  a  random 
selection of 5% of the samples within percentile range groups. 

GeoSpark Consulting has prepared several reports summarizing the control sample results received between 2004 and 
2019.  

Paired  laboratory  and  field  determinations  from  for  mineralized  zone  SG  measurements  from  1998  and  the  2004 
program show very low variation. 

SRK conducts monthly QA/QC review of kinetic test leachates for all operating kinetic tests.  

Data Verification  

Wood qualified persons reviewed database verification and laboratory QA/QC reports and made data entry error spot 
checks, inspected down hole survey results for anomalous kinks and excessive bends in the drill hole traces, reviewed 
reports summarizing the results of drill core sampling and assaying completed since 2004, reviewed the assay database 
for  gaps  and  overlaps,  and  reviewed  the  historic  re-assay  program  results.  The  following  two  significant  issues  were 
observed: 

•  A significant high bias in historic Cu and low bias in historic Pb assay results 

•  Apparent low bias in Random Forest assisted specific gravity predictions  

In the current assay table historic sample interval assay results are given priority over the historic sample interval re-
assay results. This is not expected to have a material impact on the grade estimation but using the re-assay results would 
further mitigate the risk associated with the observed biases in the historic Cu and Pb values. 

Overall,  the  database  verification  and  management  and  the  laboratory  QAQC  monitoring  completed  by  NovaGold, 
Trilogy Metals, and Ambler Metals has resulted in a reasonably reliable drill hole database suitable for supporting the 
Mineral Resource estimated for the Arctic deposit. Some deficiencies exist that when rectified will make the drill hole 
database even more robust. 

40 

 
 
Mineral Processing and Metallurgical Testing 

Since 1970, metallurgical testwork has been conducted to evaluate the ability of the Arctic deposit to produce copper, 
lead and zinc concentrates. In general, the samples tested produced similar metallurgical performances and the Arctic 
Project has seen the development of a robust metal recovery process to support the current operational plans. Work 
conducted  included  mineralogy  and  flotation  testing,  locked  cycle  tests,  comminution  tests,  copper/lead  separation 
testwork, talc optimization testwork, and thickening and filtration testing. 

Testwork can be broken into four key time periods: 

1.  Historical  testwork  completed  prior  to  2012,  primarily  by Kennecott  Research  Centre  in  Utah,  and  Lakefield 

Research Ltd., Lakefield, Ontario; 

2.  Preliminary Trilogy testwork conducted at SGS Mineral Services, Vancouver (“SGS Vancouver”), in 2012 to 2015;  

3.  Detailed Trilogy testwork conducted at ALS Metallurgy in Kamloops, BC (“ALS Metallurgy”) in 2015 to 2019; and 

4.  Amber Metals testwork conducted at ALS Metallurgy and SGS Mineral Services in 2021 to 2022. 

In 2012, SGS Vancouver conducted a metallurgical test program to further study metallurgical responses of the samples 
produced  from  Zones  1,  2,  3,  and  5  of  the  Arctic  deposit.  The  flotation  test  procedures  used  talc  pre-flotation, 
conventional copper-lead bulk flotation and zinc flotation, followed by copper and lead separation. In general, the 2012-
2015 test results indicated that the samples responded well to the flowsheet tested. The average results of the locked 
cycle tests (without copper and lead separation) were as follows: 

• 

The copper recoveries to the bulk copper-lead concentrates ranged from 89% to 93% excluding the Zone 1 & 2 
composite which produced a copper recovery of approximately 84%; the copper grades of the bulk concentrates 
were 24% to 28%. 

•  Approximately 92% to 94% of the lead was recovered to the bulk copper-lead concentrates containing 9% to 

13% lead. 

• 

The  zinc  recovery  was  84.2%  from  Composite  Zone  1  &  2,  93.0%  from  Composite  Zone  3  and  90.5%  from 
Composite Zone 5. On average, the zinc grades of the concentrates produced were higher than 55%, excluding 
the concentrate generated from Composite Zone 1 & 2, which contained only 44.5% zinc. 

•  Gold and silver were predominantly recovered into the bulk copper-lead concentrates. Gold recoveries to this 

concentrate ranged from 65% to 80%, and silver recoveries ranged from 80% to 86%. 

Using an open circuit procedure, the copper and lead separation tests on the bulk copper–lead concentrate produced 
from  the  locked  cycle  tests  generated  reasonable  copper  and  lead  separation.  The  copper  concentrates  produced 
contained approximately 28% to 31% copper, while the grades of the lead concentrates were in the range of 41% to 67% 
lead. In this testwork program, it appeared that most of the gold reported to the copper concentrate and on average the 
silver was equally recovered into the copper and lead concentrates. Subsequent testwork to better define the copper 
and  lead  separation  process  was  conducted  in  2017,  including  a  more  detailed  evaluation  of  the  precious  metal 
deportment in the copper and lead separation process. 

Grindability testing was completed during both the SGS Vancouver and ALS Metallurgy testwork programs to support 
the design and economics of efficient grinding of the Arctic materials. SAG mill test results included a single JKTech drop-
weight test and 19 SAG media competency tests using variability samples. Test results show the material is amenable to 
SAG milling and is relatively soft, with a reported breakage (axb) average value of 189.7. Bond ball mill work index (BWi) 
tests were completed on 44 samples and values ranged from 5.4 to 13.1 kWh/t with an average BWi of 8.82 kWh/t. 
Abrasion index (Ai) tests were completed on five samples and values fluctuated from 0.017 to 0.072 g for the measured 

41 

samples. The data indicate that the samples are neither resistant nor abrasive to ball mill grinding. The materials are 
considered to be soft or very soft in terms of grinding requirements. The grinding testwork was used to support detailed 
grinding circuit design. 

In 2017, ALS Metallurgy conducted detailed copper and lead separation flotation testwork using a bulk sample of copper– 
lead  concentrate  produced  from  the  operation  of  a  pilot  plant.  This  testwork  confirmed  high  lead  recoveries  in 
lockedcycle  testing  of  the  copper–lead  separation  process  and  confirmed  precious  metal  recoveries  into  the 
representative copper and lead concentrates. This testwork indicated a clear tendency of the gold values to follow the 
lead concentrate, giving it a significant gold grade and value. Detailed mineralogical analysis showed that a majority of 
gold values were occurring as liberated fine-grained gold particles. 

The conclusions of testwork conducted both in 2012 and 2017 indicate that the Arctic materials are well-suited to the 
production of high-quality copper and zinc concentrates using flotation techniques which are industry standard. Copper 
and zinc recovery data were reported in the range of 88% to 92%, which reflected the high-grade nature of the deposit 
as well as the coarse-grained nature of these minerals. Grade variations within the deposit will be observed as indicated 
by the grade variations observed in variability samples, however, mill feed variability is expected to be limited and readily 
manageable with good plant operational practices. Lead concentrates have the potential to be of good quality and can 
also be impacted by zones of very high  talc. Considerable care will be required to ensure maximum talc recovery to 
remove talc, which has the potential to dilute lead concentrate grades. The lead concentrate is also shown to be rich in 
precious metals, which has some advantages in terms of marketability of this material. 

Ancillary  testwork  was  completed  by  third  party  consultants  on  representative  concentrate  samples,  to  provide 
thickening and filtration data for the various concentrates. Settling and filtration rates were observed to be typical for 
sulfide concentrates and moisture contents in final filter cakes were observed to be lower than expected. 

Metallurgical testwork was completed to provide representative tailings samples for use in detailed solids settling and 
compaction testwork to provide data for tailings design studies. 

A detailed study of water treatment chemistry was undertaken to evaluate and confirm the option of destroying cyanide 
contained in solutions from the proposed copper–lead separation process. The use of an SO2/air process in a small-scale 
pilot plant demonstrated removal of 99% of the contained cyanide and supported the concept of maintaining low cyanide 
concentrations within the proposed tailings pond solutions. 

In 2021, various metallurgical testwork programs were conducted at ALS Metallurgy, SGS, and MO Group. ALS Metallurgy 
completed  several  testwork  programs,  including  flotation  testing  with  the  Preflotation  circuit  only  to  establish  talc 
performance;  further flowsheet  development  test  work to investigate the benefits of sequential flotation versus the 
original  bulk  flow  sheet;  and  a  variability  testwork  to  support  the  development  of  improved  metallurgical  recovery 
models.  

The objective of the ALS Metallurgy program was to investigate bulk and sequential flotation flowsheets with composites 
formed from two parent composites, and then select a flowsheet for a geo-metallurgical evaluation through testing with 
variability samples.  

The  mineralization  was  amenable  to  either  a  bulk  flowsheet  followed  by  copper-lead  separation,  or  a  sequential 
flowsheet, both following a pre-flotation stage to remove talc.  

Table 4 shows average performance obtained for the Avg Talc Composite in the Flowsheet Development phase of the 
testing. 

42 

Table 4 – Comparison of Bulk versus Sequential Locked-Cycle Test Results – ALS 2021 

Composite 

Cu 
(%) 

Pb 
(%) 

Zn 
(%) 

Ag 
(g/t) 

Au 
(g/t) 

Mg 
(%) 

Cu 

Pb 

Zn 

Ag 

Au 

Assays 

Distribution (%) 

Avg Talc Bulk 

Copper concentrate  

28.0  

0.86  

4.27  

181  

4.17  

0.46  

87.3  

8.3  

9.1  

36.0  

60.9 

Lead concentrate  

7.90  

39.0  

6.30  

1124  

4.75  

1.23  

5.1  

78.1  

2.8  

46.0  

14.3 

Zinc concentrate  

0.87  

0.38  

55.9  

41  

0.35  

0.04  

1.9  

2.6  

83.3  

5.7  

3.5 

Avg Talc - Sequential 

Copper concentrate  

27.6  

0.87  

2.05  

168  

3.23  

1.96  

90.2  

8.9  

4.7  

34.9  

48.7 

Lead concentrate  

2.72  

49.3  

9.71  

1360  

5.31  

1.40  

1.2  

69.9  

3.1  

39.4  

11.2 

Zinc concentrate  

0.98  

1.09  

54.5  

47  

0.77  

0.17  

2.1  

7.3  

83.5  

6.5  

7.7 

Copper recovery to the copper concentrate was slightly higher for the sequential flowsheet; however, gold recovery to 
the copper concentrate was substantially lower. The lead concentrate grade for the Avg Talc composite could likely be 
improved  over  that  shown  above  with  optimization  of  copper-lead  separation  conditions  given  the  higher  lead 
concentrate grade measured with other composites.  

Zinc circuit performance was similar for the two flowsheets, although higher zinc recovery to the copper concentrate 
was recorded for the bulk circuit. Magnesium content in the copper concentrate was higher for the sequential circuit, 
but similar in the lead concentrate for both circuits. 

Based on economic analysis comparing the bulk and sequential circuit, the bulk circuit flowsheet was selected for the 
Variability testing.  

An overall metallurgical balance for the project  is summarized in Table 5.  The projected metallurgical recoveries are 
based on an expected average recovery over the  life-of-mine (LOM), and results of metallurgical variability testwork 
conducted in 2021 and 2022.   

43 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 5 – Summary of Overall Metal Recovery – Arctic Project 

Concentrate Grade   

Metal Recoveries   

Process stream 

Mass 
%   

Cu 
%   

Process Feed   

100 

2.1 

Copper Conc.   

Lead Conc.   

Zinc Conc.   

6.3 

0.6 

4.7 

Tailings   

88.4 

30.3 

2.0 

1.0 

0.1 

Pb 
%   

0.5 

1.7 

53.9 

0.5 

0.1 

Zn 
%   

2.8 

0.7 

5.9 

Au 
g/t   

0.4 

3.4 

Ag 
g/t   

31.1 

Cu 
%   

- 

Pb 
%   

- 

160.5 

92.1 

19.4 

14.1 

2425.8 

61.3 

Zn 
%   

- 

1.6 

1.3 

Au 
%   

- 

Ag 
%   

- 

52.2 

32.4 

21.4 

48.8 

53.6 

0.3 

0.3 

0.1 

38.3 

4.6 

4.4 

88.4 

3.2 

5.7 

14.8 

8.7 

23.2 

13.1 

0.6 

2.2 

5.1 

SGS conducted SAG Power Index (SPI®) tests to investigate the effect of friable ores on the plant throughput.  

MO  Group  conducted  talc  circuit  modelling  using  the  data  obtained  from  the  ALS  Metallurgy  Preflotation  test  work 
program  to  investigate  the  benefits  of  talc  circuit  open  and  closed-circuit  cleaning.  The  MO  Group  also  conducted 
dewatering and filtration test work on the talc concentrate and final tailings generated from the Preflotation test work 
program.  

Thickening and filtration testwork were completed by the MO Group on representative preflotation concentrate and 
tailings samples, to investigate opportunities to improve water recovery and reduce operating costs. The results were 
used to incorporate a tailings thickener in the process plant flow sheet. 

Mineral Resource and Mineral Reserve Estimates  

Mineral Resource Estimate 

Mineral Resources have not been previously disclosed under S-K 1300 standards and definitions in a filing with the United 
States Securities and Exchange Commission (SEC). A description of the key assumptions, parameters, and methods used 
in the mineral resource estimate are included in Chapter 11 of the S-K 1300 Arctic Report  . A brief discussion of the 
material assumptions and criteria used in the mineral resource estimation are as follows:   Mineral resource estimates 
are performed from a 3D block model based on geostatistical applications using LeapFrog software. The block model has 
a parent block size measuring 10 x 10 x 5 m with a sub-block size measuring 2 x 2 x1 m and uses data derived from 171 
drill holes within the Arctic deposit. The resource estimate was generated using drill hole sample assay results and the 
interpretation  of  a  geological  model  which  relates  to  the  spatial  distribution  of  copper,  lead,  zinc,  gold  and  silver. 
Interpolation characteristics were defined based on the geology, drill hole spacing, and geostatistical analysis of the data. 
The effects of potentially anomalous high-grade sample data, composited to 2 m intervals, are controlled by capping 
each mineralization zone. The grade models have been validated using a combination of visual and statistical methods. 
The resources were classified according to their proximity to the sample data locations and are reported using the 2014 
CIM Definition Standards in the NI 43-101 Arctic Report and standards and definitions in S-K 1300 in the S-K 1300 Arctic 
Report. The tonnes, grade, and classification are the same under the two standards. Model blocks estimated by three or 
more drill holes spaced at a maximum distance of 100 m are included in the Indicated category. Inferred blocks are within 
a maximum distance of 150 m from a drill hole. 

The deposit is amenable to open pit extraction methods. Reasonable prospects for economic extraction were established 
by constraining mineralization within a pit shell based on technical and economic assumptions presented in Table 6. As 

44 

 
a result of flattening the north end of the reserve pit to stabilize the pit wall due to the presence of talc, a portion of the 
reserve pit extended beyond the resource constraining pit shell.  A second pass of resource tabulation was performed 
on the Indicated and Inferred classified blocks exterior to the resource constraining pit shell and interior to the reserve 
constraining pit shell, above a 0.5% copper equivalent (CuEq) cut-off.  The formula for the CuEq is shown in footnote 5 
of Table 7. 

Table 6 - arameters Used to Generate a Resource-Constraining Pit Shell 

Optimization Parameter 

Open Pit Mining Cost 

Milling Cost + G&A 

Pit Slope 

Copper Price 

Lead Price 

Zinc Price 

Gold Price 

Silver Price 

Metallurgical Recovery:  Copper 

Lead 

Zinc 

Gold 

Silver 

Unit 

$/t mined 

$/t processed 

degree 

$/lb 

$/lb 

$/lb 

$/oz 

$/oz 

% 

% 

% 

% 

% 

Value 

3 

35 

43 

3.00 

0.90 

1.00 

1,300 

18 

92 

77 

88 

63 

56 

Note: no adjustments for mining recovery or dilution. The metal prices and costs were fixed over the 13-year mine life.  The metal 
prices are within the range of industry consensus of long-term average metal prices based on an assessment of industry peers over 
the past year, and long-term forecast prices by banks at the time of the mineral resource estimate.  

Trilogy’s attributable interest in the Mineral Resource estimate exclusive of Mineral Reserves is stated in Table 7a. The 
Mineral Resource estimate inclusive of Mineral Reserves is stated in Table 7b . All Indicated Mineral Resources have been 
converted  to  Mineral  Reserves.  Mineral  Resources  are  reported  in  place  (point  of  reference)  and  on  a  100%  basis; 
however, Trilogy Metals attributable interest is 50% of the tonnes and metal content. The Mineral Resource estimate is 
listed in Table 7. Mineral Resources are reported inclusive of those Mineral Resources that were converted to Mineral 
Reserves. 

Table 7a – S-K 1300 Mineral Resource Summary Table, Exclusive of Mineral Reserves  

Resource 

Tonnage 

Category 

Inferred -100% 

Inferred – 50% 
Attributable 
Interest 

Notes: 

(Mt) 

4.5 

2.25 

Average Grade 

Contained Metal Content 

Cu 

(%) 

Pb 

(%) 

Zn 

(%) 

(g/t) 

1.92 

0.70 

 2.93 

0.43 

Au 

Ag 

Cu 

Pb 

Zn 

Au 

Ag 

(g/t) 

35.6 

(Mlb) 

(Mlb) 

(Mlb) 

(koz) 

(Moz) 

189 

69 

288 

62 

5 

94.5 

34.5 

144 

31 

2.5 

1.  Mineral Resources are current as of November 30, 2022 and were verified by a Wood QP. 

45 

 
 
 
 
 
 
 
 
2.  Mineral Resources were prepared in accordance with the standards and definitions of S-K 1300 and represent first-time 

disclosure of Mineral Resources under S-K 1300 standards and definitions. 

3.  Mineral Resources stated are contained within a conceptual pit shell developed using metal prices of $3.00/lb Cu, $0.90/lb 
Pb, $1.00/lb Zn, $1,300/oz Au and $18/oz Ag and metallurgical recoveries of 92% Cu, 77% Pb, 88% Zn, 63% Au and 56% Ag 
and operating costs of $3/t mining and $35/t process and general and administrative costs. The assumed average pit slope 
angle is 43º.  

4.  As a result of flattening the north end of the reserve pit to stabilize the pit wall due to the presence of talc, a portion of the 
reserve  pit  extended  beyond  the  resource  constraining  pit  shell  and  a  second  pass  of  mineral  resource  tabulation  was 
performed  exterior  to  the  constraining  resource  pit  and  interior  to  the  constraining  reserve  pit  which  is  included  in  the 
Mineral Resource tabulation. 

5.  The cut-off grade is 0.5% copper equivalent: CuEq = (Cu% x 0.92) + (Zn% x 0.290) + (Pb% x 0.231) + (Au g/t x 0.398) + (Ag g/t 

x 0.005). 

6.  The Mineral Resource estimate is reported exclusive of those Mineral Resources that were converted to Mineral Reserves.  
7.  Trilogy Metals’ 50% attributable interest is stated in the table. 
8. 

Figures may not sum due to rounding. 

Table 7b – NI 43-101 Mineral Resource Summary Table, Inclusive of Mineral Reserves 

Average Grade 

Contained Metal Content 

Resource 

Tonnage 

Cu 

Pb 

Zn 

Au 

Ag 

Cu 

Pb 

Zn 

Au 

Ag 

Confidence 
Category 

(Mt) 

(%) 

(%) 

(%) 

(g/t) 

(g/t) 

(Mlb) 

(Mlb) 

(Mlb) 

(koz) 

(Moz) 

Indicated 

35.7 

2.98 

0.79 

4.09 

0.59 

45.2 

2,347 

621 

3,216 

675 

Inferred 

4.5 

1.92 

0.70 

2.93 

0.43 

35.6 

189 

69 

288 

62 

52 

5 

Notes: 

1.  Mineral Resources are current as of November 30, 2022 and were verified by a Wood QP. 
2.  Mineral Resources were prepared in accordance with the standards and definitions of S-K 1300.  
3.  Mineral Resources stated are contained within a conceptual pit shell developed using metal prices of $3.00/lb Cu, $0.90/lb 
Pb, $1.00/lb Zn, $1300/oz Au and $18/oz Ag and metallurgical recoveries of 92% Cu, 77% Pb, 88% Zn, 63% Au and 56% Ag 
and operating costs of $3/t mining and $35/t process and G&A. The assumed average pit slope angle is 43°.  

4.  The  cut-off  grade  is  0.5%  copper  equivalent.  CuEq  =  (Cu%x0.92)  +  (Zn%x0.290)  +  (Pb%x0.231)  +  (Au  g/tx0.398)  +  (Ag 

g/tx0.005).  

5.  As a result of flattening the north end of the reserve pit to stabilize the pit wall due to the presence of talc, a portion of the 
reserve pit extended beyond the resource constraining pit shell.  Approximately 568kt of 1.72% Cu, 0.77% Pb, 0.23 g/t Au 
and 21.3 g/t Ag in the Indicated category, and approximately 319 kt of 2.01% Cu, 0.87% Pb, 2.53% Zn, 0.50 g/t Au and 37.5 
g/t Ag in the Inferred category were added to the Mineral Resource tabulation. 

6.  The Mineral Resource estimate is reported inclusive of those Mineral Resource that were converted to Mineral Reserves.   
7.  Trilogy Metals’ attributable interest is 50% in the table. 
8. 

Figures may not sum due to rounding. 

Factors that may affect the mineral resource estimate are listed below: 

•  Uncertainties in sampling and drilling methods, data processing and handling. 

•  Metal price assumptions. 

•  Uncertainties in the cost assumptions used to determine the cut-off grade. 

•  Uncertainties in the geological and mineralization shapes, and geological and grade continuity assumptions. 

46 

 
•  Uncertainties in the historically predicted (estimated) SG values determined by Random Forest Regressor. 

•  Uncertainties in the geotechnical, mining, and metallurgical recovery assumptions. 

•  Uncertainties represented by historical assay values for payable metals. 

•  Uncertainties  in  the  resource  estimation  parameters  including  parameters  such  as  capping  values,  search 

ellipsoids, variogram models, number of composites. 

• 

Changes in the Mineral Resource Classification criteria. 

•  Uncertainties to the input and design parameter assumptions that pertain to the conceptual pit constraining 

the estimates. 

•  Uncertainties in the assumptions made to the concentrate marketability, payability and penalty terms. 

•  Uncertainties in the assumptions regarding the continued ability to access the site, retain mineral and obtain 
surface  rights  titles,  obtain  environment  and  other  regulatory  permits,  and  maintain  the  social  license  to 
operate. 

Mineral Reserve Estimates 

Mineral Reserves have not been previously disclosed under S-K 1300 standards and definition in a filing with the SEC. A 
description  of  the  key  assumptions,  parameters,  and  methods  used  in  the  mineral  reserve  estimate  are  included  in 
Chapter 12 of the S-K 1300 Arctic Report . A brief discussion of the material assumptions and criteria used in the mineral 
reserve estimation are as follows: Mineral Reserves were classified in accordance with the CIM Definition Standards for 
Mineral  Resources  and  Mineral  Reserves  (May  10,  2014)  in  the  NI  43-101  Arctic  Report  and  in  accordance  with  the 
standards and definitions of S-K 1300 in the S-K 1300 Arctic Report.  There are no differences in the resulting tonnes, 
grade, or classification between the two reporting standards. Modifying factors were applied to the Indicated Mineral 
Resources  to  convert  them  to  Probable  Mineral  Reserves.  All  of  the  Indicated  Mineral  Resources  were  converted  to 
Probable Mineral Reserves. The point of reference for reporting the Mineral Reserves is at delivery to the mill, as such, 
the Mineral Reserves for the Arctic deposit incorporate appropriate mining dilution and mining recovery estimations. 

The pit shell that defines the ultimate pit limit was derived in Whittle using the Pseudoflow pit optimization algorithm. 
The optimization procedure uses the block value and pit slopes to determine a group of blocks representing pits of valid 
slopes  that  yield  the  maximum  profit.  The  block  value  is  calculated  using  information  stored  in  the  geological  block 
model, commodity prices, mining and processing costs, process recovery, and the sales cost for the metals produced. 
The pit slopes are used as constraints for removal precedence of the blocks (Xiaoyu Bai, et al., 2017). Table 8 provides a 
summary of the primary optimization inputs.  Metal prices and costs were fixed over the 13-year mine life . 

Table 8 – Optimization Inputs 

Parameter 

Unit 

Value 

Cu Conc. 

Pb Conc. 

Zn Conc. 

Copper 

Lead 

Zinc 

Gold 

$/lb 

$/lb 

$/lb 

$/oz 

Metal Prices 

3.46 

0.91 

1.12 

1,615 

47 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Parameter 

Silver 

Discount Rate 

Dilution and Mine Losses 

Reference Bench Elevation 

Base Cost 

Incremental Mining Cost 

Unit 

$/oz 

% 

% 

m 

$/t 

Uphill (below 790m) 

Downhill (above 790m) 

$/t/5m 

$/t/5m 

Cu Conc. 

Pb Conc. 

Zn Conc. 

Value 

21.17 

8 

Estimated in a block-by-block basis, adding up 30% to 40%. 

Mining Cost 

790 

2.52 

0.02 

0.012 

Process Costs 

Operating Cost 

$/t milled 

18.31 

G&A  

Sustaining Capital 

Road Toll Cost 

Closure  

$/t milled 

$/t milled 

$/t milled 

$/t milled 

Processing Rate 

kt/d 

5.83 

2.37 

8.04 

4.27 

10 

Process Recovery  

Copper 

Lead 

Zinc 

Gold 

Silver 

Payable – Main Element 

% 

% 

% 

% 

% 

% 

Treatment Cost 

$/dmt 

Refining Cost 

Copper 

Gold 

Silver 

$/lb 

$/oz 

$/oz 

Transport Cost 

$/dmt 

Concentrate Losses 

% weight 

271 

0.42 

48 

89.9 

8.1 

3.4 

10.9 

26.4 

96.5 

80 

0.08 

5 

0.5 

2.4 

79 

0.4 

62.1 

63.1 

95 

160 

- 

10 

1.25 

2.7 

2.2 

90.6 

5.4 

3.4 

85 

215 

- 

- 

- 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Parameter 

Insurance Cost 

Unit 

% 

Representation/Marketing 

$/wmt 

Value 

Cu Conc. 

Pb Conc. 

Zn Conc. 

0.15 

2.5 

Slope Angles 

Geotechnical Sector 1 (2L-E) 

degrees 

Variable based on slope dip direction. IRA ranging from 26 to 56. 

Geotechnical Sector 2 (2L-W) 

degrees 

Variable based on slope dip direction IRA ranging from 38 to 56. 

Geotechnical Sector 3 (2U) 

degrees 

Variable based on slope dip direction IRA ranging from 29 to 56. 

Geotechnical Sector 4 (3) 

degrees 

Variable based on slope dip direction IRA ranging from 30 to 56. 

Geotechnical Sector 5 (4L) 

degrees 

Variable based on slope dip direction IRA ranging from 34 to 56. 

Geotechnical Sector 6 (4U) 

degrees 

Variable based on slope dip direction IRA ranging from 37 to 56. 

NANA Surface Use 

%NSR 

1 

Note:  IRA = inter ramp angle 

Royalties 

The  Mineral  Reserves  statement  is  shown  in  Table  9Trilogy  Metals  attributable  interest  is  50%  of  the  tonnes  of  the 
Mineral Reserves. 

Table 9 – Mineral Reserve Estimate  

Confidence Category 

Probable Mineral Reserves – 100% 

Probable Mineral Reserves – 50% 
Attributable Interest 

Notes: 

Tonnage 

Mt 

46.7 

23.35 

Average Grades 

Cu (%) 

Pb (%) 

Zn (%) 

Au (g/t) 

Ag (g/t) 

2.11 

0.56 

2.90 

0.42 

31.8 

1.  Mineral Reserves estimates are current as of November 30, 2022 and were prepared by a Wood QP. 
2.  Mineral Reserves were estimated assuming open pit mining methods and  include a combination of internal and contact 
dilution.  Total  dilution  is  expected  to  be  between  30%  and  40%.  Pit  slopes  vary  by  sector and  range  from  26°  to  56°.  A 
marginal NSR cut-off of $38.8/t is used. 

3.  Mineral Reserves are based on prices of $3.46/lb Cu, $0.91/lb Pb, $1.12/lb Zn, $1,615/oz Au, and $21.17/oz Ag. 
4.  Variable process recoveries averaging 92.2% Cu in Cu concentrate, 62.2% Pb in Pb concentrate, 87.6% Zn in Zn concentrate, 
16.0% Pb in Cu concentrate, 1.9% Zn in Cu concentrate, 47.2% Au in Cu concentrate, 32.7% Ag in Cu concentrate, 0.8% Cu 
in  Pb  concentrate,  1.3%  Zn  in  Pb  concentrate,  26.1%  Au  in  Pb  concentrate,  48.7%  Ag  in  Pb  concentrate,  2.1%  Cu  in  Zn 
concentrate, 4.5% Pb in Zn concentrate, 3.3% Au in Zn concentrate, 5.8% Ag in Zn concentrate. 

5.  Mineral Reserves are based on mining cost of $2.52/t incremented at $0.02/t/5m and $0.012/t/5m below and above 790 m 

elevation, respectively. 

6.  Costs applied to processed material following: process operating cost of $18.31/t, G&A of $5.83/t, sustaining capital cost of 

$2.37/t, closure cost of $4.27/t, road toll cost of $8.04/t. 
Strip ratio (waste:ore) is 7.3:1. 
Selling terms following: payables of 96.5% of Cu, 95% of Pb and 85% of Zn, treatment costs of $80/t Cu concentrate, $160/t 
Pb concentrate and $215/t Zn concentrate; refining costs of $0.08/lb Cu in Cu concentrate, and$10/oz Au, $1.25/oz Ag in Pb 
concentrate; and transport cost $270.98/t concentrate. 
Fixed royalty percentage of 1% NSR. 

7. 
8. 

9. 

49 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
10.  Trilogy Metals’ attributable interest is 50% of the tonnage stated in the table. 

The Arctic Mineral Reserves are subject to the types of risks common to open pit polymetallic mining operations that 
exist in Alaska and may be materially affected by the following risk factors include: 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

Changes in the metal prices from what was assumed; 

Changes to the assumptions used to generate the cut-offs; 

Changes in local interpretations of mineralization geometry and continuity of mineralized zones; 

Changes to geological and mineralization shapes, and geological and grade continuity assumptions; 

Changes to density and domain assignments from what was assumed; 

Changes to geotechnical, hydrogeological design assumptions; 

Changes to mining and metallurgical recovery assumptions; 

Change  to  the  input  and  design  parameter  assumptions  that  pertain  to  the  open  pit  constraining  the 
estimates;  

Assumptions as to concentrate marketability, payability and penalty terms; 

Assumptions as to the continued ability to access the site, retain mineral tenure and obtain surface rights 
titles, obtain environment and other regulatory permits, and maintain the social license to operate. 

More specifically the presence of certain talc layers in the rock have not been included in the current geological model 
and could affect the metallurigcal recoveries and slope stability.  Additionally, there is currently no developed surface 
access  to  the  Arctic  Project  area  and  beyond.  Access  to  the  Arctic  Project  is  proposed  to  be  via  AAP,  a  road 
approximately 340 km (211 miles) long, extending west from the Dalton Highway where it would connect with the 
proposed Arctic Project area. Construction costs of the road are not yet final. The working assumption is that AIDEA 
would arrange financing in the form of a public-private partnership to construct and arrange for the construction and 
maintenance of the access road. AIDEA would charge a toll to multiple mining and industrial users (including the Arctic 
Project) in order to pay back the costs of financing the AAP. The amount paid in tolls by any user would be affected by 
the cost of the road, its financing structure, and the number of mines and other users of the road which could also 
include commercial transportation of materials and consumer items that would use the AAP to ship concentrates to 
the Port of Anchorage in Alaska and possibly provide goods and commercial materials to villages in the region. 

The Mineral Reserve estimation assumes toll payments of $5.52/t processed, plus a road maintenance fee of $2.52/t 
milled processed, resulting in a total road toll and maintenance LOM unit cost of $8.04/t processed.  There is a risk that 
a negotiated road toll agreement may result in higher costs than what has been assumed. 

Mining Operations 

The Arctic Project is designed as a conventional truck-shovel operation with 144 t trucks and 15 m3 shovels. The pit design 
includes four nested phases to balance stripping requirements while satisfying the concentrator requirements. 

The design parameters include a ramp width of 30 m, road grades of 10%, bench height of 5 m, targeted mining width 
between 70 m and 100 m, berm interval of 20 m, variable slope angles by sector and a minimum mining width of 30 m. 

The smoothed final pit design contains approximately 46.7 Mt of ore and 340.2 Mt of waste for a resulting stripping ratio 
of 7.3:1. Within the 46.7 Mt of ore, the average grades are forecasted to be 2.11% Cu, 2.90% Zn, 0.56% Pb, 0.42 g/t Au 
and 31.8 g/t Ag. 

50 

The scheduling constraints set the maximum mining capacity at 35 Mt/a, and the maximum process capacity at 10 kt/d. 
The production schedule based on the Probable Mineral Reserves shows a total life-of-mine (LOM) of 15 years, including 
2 years of pre-production and 13 years of production. 

Processing and Recovery Operations 

The 10,000 t/d process plant design is conventional for the industry and will operate two 12-hour shifts per day, 365 d/yr 
with an overall plant availability of 92%. The process plant will produce three concentrates: 1) copper concentrate, 2) 
zinc concentrate, and 3) lead concentrate. Gold and silver are expected to be payable at a smelter; both gold and silver 
is expected to be payable in the copper and lead concentrates. 

While there are several deleterious elements reporting to the concentrates at levels that could incur penalties, there are 
no special processing provisions required to make a readily saleable concentrate. The presence of naturally hydrophobic 
talc minerals was consistently observed in the various testwork programs. There is little reason to expect concentrates 
will be impaired by talc contamination as talc can be effectively removed from the flotation process prior to base metal 
flotation. Talc and fluorine levels will be managed by optimization of the talc pre-float circuit, effectively removing talc 
and fluorine to ensure the quality of the lead concentrate. 

The mill feed will be hauled from the open pit to a primary crushing facility where the material will be crushed by a jaw 
crusher to a particle size of 80% passing 80 mm. 

The crushed material will be ground by two stages of grinding, consisting of one SAG mill and one ball mill in closed 
circuit with hydrocyclones (SAB circuit). The hydrocyclone overflow with a grind size of approximately 80% passing 70 
μm will first undergo talc pre-flotation, and then be processed by conventional bulk flotation (to recover copper, lead, 
and associated gold and silver), followed by zinc flotation. The bulk rougher concentrate will be cleaned and followed by 
copper and lead separation to produce a lead concentrate and a copper concentrate. The final tailings from the zinc 
flotation circuit will be pumped to a tailing management facility (“TMF”). Copper, lead, and zinc concentrates will be 
thickened and pressure-filtered before being transported by truck to a port and shipped to smelters. 

Based on the mine plan developed for the NI 43-101 Arctic Report and S-K 1300 Arctic Report and metallurgical testwork 
results, the LOM average metal recoveries and concentrate grades are presented in table 10. 

Table 10 – LOM average recovery and grade 

Description 

Units 

Cu con 

LOM Production 

Grade 

Recovery 

t/y 

% 

% 

234,132 

30.3% Cu 

92.1% Cu 
52.2% Au 
32.5% Ag 

Pb con 

23,300 

53.9% Pb 

61.3% Pb 
21.6% Au 
48.6% Ag 

Zn con 

174,202 

53.7% Zn 

88.5% Zn 

The recovery plan includes provision for reagents, and water and power requirements. 

Infrastructure, Permitting and Compliance Activities 

Infrastructure 

The Arctic Project site is a remote, greenfield site that is remote from existing infrastructure. Infrastructure that will be 
required for the mining and processing operations will include: 

51 

 
 
 
 
 
 
•  Open pit mine 

• 

• 

• 

Stockpiles and Waste Rock Facility (“WRF”) 

Truck workshop, truck wash, mine offices, mine dry facility and warehouse 

Power house 

•  Administration building 

•  Mill dry facility 

• 

• 

• 

• 

• 

Plant workshop and warehouse 

Primary crushing building 

Fine ore stockpile building 

Process plant and laboratory 

Concentrate loadout building 

•  Reagent storage and handling building 

• 

Explosive storage silos and magazines 

•  Avalanche mitigation structures 

• 

• 

TMF 

Surface water diversion and collection channels, culverts, and containment structures 

•  Waste rock collection pond (“WRCP”) 

• 

Process water pond 

•  Water treatment plant (“WTP”) 

• 

Camp 

Access 

The Arctic Project site will be accessed through a combination of State of Alaska-owned highways (existing), an AIDEA-
owned  private  road  (proposed)  and  Ambler-owned  access  roads  (proposed).  The  AAP  road  is  proposed  by  AIDEA  to 
connect the Ambler Mining District to the Dalton Highway. The AAP road expected to be permitted as a private road with 
restricted access for industrial use. To connect the Arctic Project site and the existing exploration camp to the proposed 
AAP road, an access road (the Arctic access road) will need to be built. 

The State of Alaska-owned, public Dahl Creek airport will require upgrades to support the planned regular transportation 
of crews to and from Fairbanks. The cost of these upgrades has been included in the capital cost estimate. 

52 

 
 
Power 

Power generation will be by five diesel generators, producing a supply voltage of 13.8 kV. The total connected load will 
be 25.9 MW with a normal running load of 21.0 MW. Diesel will be supplied via existing fuel supply networks in the 
region and shipped along the AAP road. 

Accommodation 

The Arctic Project will require three self-contained camps, in two different locations, equipped with their own power 
and heat generation capabilities, potable water treatment plant, sewage treatment plant, and garbage incinerator. The 
existing 90-person Bornite Camp currently used for exploration will be expanded and used to start the construction of 
the Arctic access road and the logistics yard and construction camp. This Bornite Camp will be expanded and available 
prior to surface access from the Dalton Highway via the AAP road is available. A 250-person construction camp (“CC”) 
will be constructed at location near the intersection of the AAP road and Arctic Mine Access road, across the road from 
the Logistics Yard. CC will be constructed when limited access via the AAP is available for the transport of camp modules. 
A Permanent Accommodations Facility (“PAF”) will be constructed in the same location as CC. The PAF will be constructed 
when the AAP is available to transportation of the modules by truck and will be operating for about 2 years prior to the 
commissioning of the Arctic Mill and production of concentrates. During this period, it will be used to accommodate both 
construction  personnel  and  the  initial  Ambler  Metals  Mine  Operations  and  support  personnel  required  for  pre-
production mining.  

Waste Rock Facility 

The WRF will be developed north of the Arctic pit in the upper part of the Subarctic Creek valley. The WRF is designed as 
part  of  the  tailings  dam  structure  to  provide  a  buttress  for  tailings  containment  in  the  adjacent  footprint.  The  total 
volume of waste rock is expected to be 162.6 Mm3 (340 Mt); however, there is potential for expanded volume in the 
waste if placement density is <2.0 t/m3. The WRF will have a final height of 340 m to an elevation of 990 masl and is 
planned to be constructed in lifts of either 5, 10 or 20 m height with catch benches every 20 m to achieve an overall 
slope angle of 2.5H:1V. 

Most of the waste rock is anticipated to be potentially acid-generating and there will be no separation of waste based 
on acid generation potential. Rather, seepage from the WRF will be collected and treated. 

Overburden Stockpiles 

There will also be three small overburden stockpiles to store the stripped topsoil and overburden from the TMF and WRF 
footprint. The topsoil stockpile will be placed between the haul roads with capacity to store up to 325,000 m3 while the 
overburden stockpile will be located south of the WRF to store up to 2,200,000 m3. 

Tailings Management Facility 

The TMF will be located at the headwaters of Subarctic Creek, in the upper-most portion of the creek valley. The 59 ha 
footprint of the TMF will be fully lined with a geomembrane liner. Tailings containment will be provided by an engineered 
dam, buttressed by the WRF that will be constructed immediately downstream of the TMF and the natural topography 
on the valley sides. A starter dam will be constructed to elevation 830 m. Three subsequent raises will bring the final 
dam crest elevation to 892 m, which is 98 m lower than the final elevation of the WRF. The TMF is designed to store 
approximately 37.4Mm3 (41.2 Mt) of tailings produced over the 13-year mine life, 3.3 Mm3 of additional pond water, as 
well as 1.5 times the probable maximum flood, with 2.5 m of freeboard. 

Water Management 

The proposed mine development is located in the valley of Subarctic Creek, a tributary to the Shungnak River. A surface 
water management system will be constructed to segregate contact and non-contact water. Non-contact water will be 

53 

diverted around mine infrastructure to Subarctic Creek. A groundwater seepage monitoring and collection system will 
be located down gradient of the WRF and seepage collection pond. Contact water will be conveyed to treatment facilities 
prior to discharge to the receiving environment. 

A WRCP will be located directly below the toe of the WRF and will be used to collect seepage from the WRF, runoff from 
the WRF and haul road corridor area, and water pumped from the open pit. 

The Arctic Project water and load balance model was updated to include the current water management plan. The model 
indicates that during operations, excess water from the WRCP will need to be treated prior to discharge to the receiving 
environment. During closure, water from the dewatering of the TMF will also need to be treated prior to discharge to 
the receiving environment. 

Water Treatment Plant 

It was assumed the site will be assigned water quality-based effluent limits matching the state’s Water Quality Standards 
for the nearby Subarctic Creek. Therefore, the WTP is designed to treat all parameters in the predicted site wastewater 
to the WQS of Subarctic Creek. This will eliminate the need for a mixing zone and allow treated water to be discharged 
year-round if needed. 

A single WTP, built in stages, will be used. During Operations phase the WTP will treat effluent from the WRCP, and 
during Closure phase effluent from the pit. The WTP will initially consist of chemical/physical treatment with reverse 
osmosis  (“RO”)  filtration.  During  operations,  the  RO  reject  will  be  sent  to  the  TMF,  and  only  RO  permeate  will  be 
discharged to Subarctic Creek. When the TMF is closed at the end of the operations, a biological/chemical/physical plant 
will be added to treat the RO reject. The biologic plant discharge will be mixed with the RO prior to discharge. 

Market Studies 

Metal pricing was guided by 3-year trailing average prices and long-term price forecasts from analysts as published by 
CIBC in 2022.  

The metal price assumptions used in the economic analysis: 

• 

• 

• 

Copper:  $3.65/lb 

Zinc:  $1.15/lb 

Lead:  $1.00/lb 

•  Gold:  $1,650/oz 

• 

Silver:  $21.00/oz 

Smelter terms were prepared in January 2023 by StoneHouse Consulting Inc. Smelter terms were applied for the delivery 
of copper, zinc and lead concentrate. It was assumed that delivery of all concentrates would be to a smelter in the Asia 
Pacific region at currently available freight rates. Total transport costs for the concentrate are estimated at $324.37/dmt. 

Environmental, Permitting, Social and Closure Considerations 

Environmental Considerations 

The  Arctic  Project  area  includes  the  Ambler  lowlands  and  Subarctic  Creek  within  the  Shungnak  River  drainage.  A 
significant amount of baseline environmental data collection has occurred in the area including surface and groundwater 
quality  sampling,  surface  hydrology  monitoring,  wetlands  mapping,  aquatic  life  surveys,  avian  and  mammal  habitat 
surveys, cultural resource surveys, hydrogeology studies, meteorological monitoring, and ML/ARD studies. 

54 

Permitting Considerations 

Current mineral exploration activities are conducted at the Arctic deposit under State of Alaska and NWAB permits. The 
State  of  Alaska  Miscellaneous  Land  Use  Permit  and  the  NWAB  Permit  both  expired  at  the  end  of  2022  and  will  be 
renewed. 

Mine  development  permitting  will  be  largely  driven  by  the  underlying  land  ownership  with  regulatory  requirements 
varying  depending  on  land  ownership.  The  Arctic  Project  area  includes  patented  mining  claims  (private  land  under 
separate ownership by Ambler Metals and NANA), State of Alaska land, and NANA land (private land) 

Because the infrastructure for the Arctic Project is situated to a large extent on State land, it will likely be necessary to 
obtain a Plan of Operation Approval (which includes the Reclamation Plan and Closure Cost Estimate) from the Alaska 
Department  of Natural Resources (“ADNR”). The Arctic Project  will also require certificates to construct and operate 
dams (tailings and water storage) from the ADNR (Dam Safety Unit) as well as water use and discharge authorizations, 
an upland mining lease and a mill site lease, as well as several minor permits including those that authorize access to 
construction material sites from ADNR. 

The  Alaska  Department  of  Environmental  Conservation  (“ADEC”)  would  authorize  waste  management  under  an 
Integrated Waste Management permit, air emissions during construction and operations under an air permit, and an 
Alaska Pollutant Discharge Elimination System permit for any wastewater discharges, and a Multi-Sector General Permit 
for stormwater discharges. The ADEC would also be required to review the US Army Corps of Engineers Section 404 
permit to certify that it complies with Section 401 of the Clean Water Act (“CWA”). 

The Alaska Department of Fish and Game would have to authorize any culverts or bridges that are required to cross fish-
bearing streams or other impacts to fish-bearing streams that result in the altering or affecting fish habitat. 

The U.S. Army Corps of Engineers (“USACE”) would require a CWA Section 404 permit for dredging and filling activities 
in Waters of the United States including jurisdictional wetlands. The USACE Section 404 permitting action would require 
the USACE to comply with the NEPA and, for a project of this magnitude, the development of an Environmental Impact 
Statement (“EIS”) is anticipated. The USACE would likely be the lead federal agency for the NEPA process. As part of the 
Section 404 permitting process, the Arctic Project will have to meet USACE wetlands guidelines to avoid, minimize and 
mitigate impacts to waters of the US including wetlands. 

The Arctic Project will also have to obtain approval for a Master Plan from the NWAB. In addition, actions will have to be 
taken to change the borough zoning for the Arctic Project area from Subsistence Conservation and General Conservation 
to Resource Development and Transportation. 

The overall timeline required for permitting would be largely driven by the time required for the NEPA process, which is 
triggered by the submission of the Section 404 permit application to the USACE. The timeline includes the development 
and publication of a draft and final EIS and ends with a Record of Decision and Section 404-permit issuance. In Alaska, 
the EIS and other State and Federal permitting processes are generally coordinated so that permitting and environmental 
review  occurs  in  parallel.  The  NEPA  process  could  require  about  three  years  to  complete  and  could  potentially  take 
longer. 

Social and Community 

The Arctic Project is located approximately 40 km northeast of the villages of Shungnak and Kobuk, and 65 km east-
northeast of the community of Ambler.  The population in these villages are 151 in Kobuk (2020 Census), 210 in Shungnak 
(2020 Census), and 275 in Ambler (2020 Census). Residents largely live a subsistence lifestyle with incomes supplemented 
by guiding, local development projects, employment through tribal and city councils, government aid, and employment 
both in and outside of their home villages.   

55 

The  Arctic  Project  has  the  potential  to  significantly  improve  work  opportunities  for  residents  during  the  exploration 
phase, construction, and during full operation.  Trilogy’s joint  venture, Ambler Metals works directly with the  Upper 
Kobuk villages and communities throughout the region to employ residents as mechanics, geotechnicians, core cutters, 
administrative staff, camp services, heavy equipment operators, drill helpers, and environmental technicians.   

Stakeholder  outreach  and  community  meetings  in  the  region  by  the  Arctic  Project’s  owners  over  many  years  have 
provided the opportunity to engage with residents, provide updated information on the project and future plans for the 
Upper Kobuk Mineral Project, hear concerns, answer questions, and build relationships.  

This engagement has also identified various hurdles residents have faced when applying for employment. Opportunities 
have been created for NANA shareholders to apply and receive educational scholarships, participate in job shadowing at 
Bornite, driver’s license courses, and heavy equipment operator training sponsored by the Arctic Project’s owners.   

It is the company’s goal to continue and grow these efforts throughout the permitting process and the life of the project 
– encouraging and supporting education, job training, employment, and economic growth. 

Closure Planning 

Mine reclamation and closure are largely driven by State of Alaska regulations that specify that a mine must be reclaimed 
concurrent with mining operations to the greatest extent possible and then closed in a way that leaves the site stable in 
terms of erosion and manages degradation of water quality from acid rock drainage or metal leaching on the site. A 
detailed Reclamation Plan and Closure Cost Estimate will be submitted to the State of Alaska agencies for review and 
approval in the future, during the formal mine permitting process. 

Owing to the fact that the Arctic Project is likely to have facilities on a combination of private (patented mining claims 
and native land) and State land, the Reclamation Plan will be submitted and approved as part of the Plan of Operations, 
which is approved by the ADNR. However, since the Reclamation and Closure plan must meet regulations of both ADNR 
and the ADEC, both agencies will review and approve the Reclamation Plan and Closure Cost Estimate. In addition, private 
landowners must formally concur with the portion of the Reclamation Plan for their lands so that it is compatible with 
their intended post-mining land use. 

The estimated closure costs are determined from unit rates based on projects located in Alaska. The indirect costs were 
included as percentages of the estimated direct costs. Long-term water treatment and maintenance of certain water 
management  facilities were calculated separately, and a net  present  value (“NPV”)value is provided for the first  100 
years, at a discount rate of 4.3%.  

Annual undiscounted costs associated with long-term operations of the WTP are estimated to be $11.7 million in Phase 
1 closure (15-years post-closure) and $10.8 million in Phase 2 closure (85 years thereafter), amounting to $1,095 million 
over the 100-year closure period. These costs equate to 258 million when discounted at 4.3% p.a. to the first year of 
post-production. 

Capital and Operating Costs 

Capital Costs  

The capital cost estimate has an estimated accuracy of ±15% and uses Q3/Q4-2022 US dollars as the base currency. The 
total estimated initial capital cost for the design, construction, installation, and commissioning of the Arctic Project is 
estimated to be $1,177 million. A summary of the estimated initial capital cost, sustaining capital cost and closure costs 
is shown in Table 11. 

56 

WBS 
Level 1 

1000  

2000  

3000  

4000  

5000  

6000  

7000  

8000  

9000  

Table 11 – Capital Cost Summary 

WBS Level 1 Description 

Initial Capex 
($ M) 

Sustaining 
Capex 
($ M) 

Total Capex 
($ M) 

Mining   

Crushing  

Process Plant  

Tailings  

On-site Infrastructure  

Off-site Infrastructure  

 Sub-total Direct Costs 

Indirects 

Provisions (Contingency)  

Owner Costs  

Sub-total Indirect Costs   

277.4 

42.5 

158.0 

88.3 

172.8 

75.8 

834.1 

177.4 

138.5 

26.8 

342.7 

Project Total  

1,176.8 

Project Total – Closure Costs 

17.5  

0  

1.3 

32.4  

35.1 

0  

86.3 

15.1 

13.0 

0 

28.1 

114.4 

294.9 

42.5 

159.3 

120.7 

207.9 

75.8 

920.4 

192.5 

151.5 

26.8 

370.8 

1,291.2 

170.8 

Operating Costs 

An average operating cost was estimated for the Arctic Project based on the proposed mining schedule. These costs 
included, mining, processing, G&A, surface services, and road toll costs. The average LOM operating cost for the Arctic 
Project is estimated to be $59.83/t milled. The breakdown of costs in Table 12 is estimated based on the LOM average 
mill feed rate of 3,650,000 t/y. 

All  pre-production  costs  have  been  included  in  the  capital  cost  estimate  in  “Properties  –  Arctic  Project—Capital  and 
Operating Costs – Capital Costs” above. 

57 

 
 
 
 
 
 
Table 12 – Overall Operating Cost Estimate 

Description 

Mining* 
Processing 
G&A 
Road Toll and Maintenance 
Water Treatment 
Total Operating Cost 

  * Excludes pre-production costs 

Economic Analysis 

LOM Average Unit 
Operating Cost 
($/ t milled) 

Percentage of Total 
Annual 
Operating Costs 

22.49 
22.60 
5.85 
7.72 
1.17 
59.83 

37.6% 
37.8% 
9.8% 
12.9% 
2.0% 
100% 

The results of the economic analyses discussed in this section represent forward-looking information as defined under 
Canadian  securities  law.  The  results  depend  on  inputs  that  are  subject  to  several  known  and  unknown  risks, 
uncertainties,  and  other  factors  that  may  cause  actual  results  to  differ  materially  from  those  presented  herein. 
Information  that  is  forward-looking  includes  the  following:  Proven  and  Probable  Mineral  Reserves  that  have  been 
modified from Measured and Indicated Mineral Resource estimates; assumed commodity prices and exchange rates; 
proposed mine and process production plan; projected mining and process recovery rates; ability to market the three 
types of concentrate on favourable terms; ability to control the levels of deleterious elements in some of the concentrate 
batches;  sustaining  costs  and  proposed  operating  costs;  assumptions  as  to  closure  costs  and  closure  requirements, 
including  WTP  requirements;  assumptions  as  to  development  of  the  Ambler  Access  Project,  timeframe  of  such 
development  and  assumed  toll  charges;  assumptions  as  to  ability  to  permit  the  project;  assumptions  about 
environmental, permitting and social risks. 

An economic analysis was undertaken on a 100% project ownership basis to determine the internal rate of return (“IRR”), 
NPV and payback on initial investment of the Arctic Project. Trilogy holds a 50% interest in the Arctic Project though its 
ownership in Ambler Metals. The Arctic Project  consists of a three-year construction period, followed by 13 years of 
production. 

The  pre-tax  financial  model  incorporated  the  production schedule  and smelter  term  assumptions  to  produce  annual 
recovered payable metal, or gross revenue, in each concentrate stream by year. Off-site costs, including the applicable 
refining  and  treatment  costs,  penalties,  concentrate  transportation  charges,  marketing  and  representation  fees,  and 
royalties were then deducted from gross revenue to determine the NSR. The operating cash flow was then produced by 
deducting annual mining, processing, G&A, surface services, and road toll & maintenance charges from the NSR. Initial 
and sustaining capital was deducted from the operating cash flow in the years they occur, to determine the net cash flow 
before taxes. Initial capital cost includes all estimated expenditures in the construction period, from Year -3 to Year -1 
inclusive.  First  production  occurs  at  the  beginning  of  Year  1.  Sustaining  capital  expenditure  includes  all  capital 
expenditures  purchased  after  first  production,  including  mine  closure  and  rehabilitation.  The  model  includes  an 
allocation of a 1% NSR attributable to NANA. 

With total capital costs of $1,719 million over LOM ($1,177 million initial capital cost, $114 million sustaining capital cost 
and $428 million closure costs), the project demonstrates a pre-tax NPV of $1,500 million at an 8% discount rate, IRR of 
25.8% and payback period of 2.9 years. Post-tax financials have an NPV of $1,108 million at an 8% discount rate, IRR of 
22.8% and payback period of 3.1 years.  

The  estimated  cash  flow  forecast  over  LOM  is  $3,942.6  million  undiscounted  pre-tax  cash  flow,  $1,500.3  million 
discounted pre-tax cash flow at an 8% discount  rate, $3,019.9 million undiscounted post-tax cash flow and $1,108.1 
discounted post-tax cash flow at an 8% discount rate. 

58 

 
 
 
Sensitivity Analysis 

Ausenco investigated the sensitivity of the Arctic Project’s pre-tax NPV, and IRR to several project variables. The following 
variables were elected for this analysis: 

• 

• 

• 

Copper price 

Zinc price 

Lead price 

•  Gold price 

• 

• 

Silver price 

Capital costs 

•  On-site operating costs 

•  Off-site  operating  costs  (royalties,  refining  and  treatment  charges,  penalties,  insurance,  marketing,  and 

representation fees, and concentrate transportation). 

Each variable was changed in increments of 10% between -20% to +20% while holding all other variables constant. The 
project NPV at an 8% discount rate is most sensitive to changes in copper price, followed by off-site operating costs, on-
site operating costs, zinc price, capital costs, silver price, gold price and lead price. 

Exploration, Development, and Production  

Constraints and Interfaces  

The Arctic Project will be an integrated development with several consultants contributing to the overall design process. 
Specialist  contractors  will  most  likely  be  engaged  for  specific  packages,  such  as  the  Arctic  access  road,  and  the 
construction camps, generally on a “design and construct” basis. 

It is essential that these parties work together to ensure data being used is both current and meaningful. Data transfer 
between parties shall be strictly controlled and in accordance with Document Control protocols. 

The early design interfaces for the Arctic Project will include at least: 

•  Mine development 

•  Waste Rock placement and Tails Dam 

•  Arctic Project water management and treatment 

•  Arctic Access Road design and construction, in particular the pioneer road necessary to allow earliest possible 

access to the Mine pre-assembly construction site 

•  Bornite, Construction and Permanent Camps. 

The Interface Management procedures will be developed to ensure services at the battery limits are clearly defined and 
understood by all parties affected. 

59 

 
Key Project Milestones  

Key project milestones will be developed once the project is committed to construction and the required permits are in 
hand. 

The  Mine  requires  nominally  two  years  of  pre-strip  operations,  tailings  pond  starter  dam  development  and  water 
accumulation before actual production mining operations can commence. 

For  that  pre-strip  work  to  start,  the  Arctic  access  road  from  the  AAP  intersection  to  the  mine  site  will  have  to  be 
constructed to at least a pioneer road condition that will allow the mine fleet and the support facilities to be delivered, 
built and made operational. 

Tailings pond construction must be to a height to allow natural collection of water in quantities that will allow plant 
operations to commence. 

Proven Technology  

The  Arctic  Project  will  utilize  proven  technology  and  equipment  that  can  be  built,  operated  and  maintained  under 
adverse weather conditions. 

The  Design  Criteria,  Technical  Specifications  and  Data  sheets  shall  reflect  the  location,  the  environmental  and  initial 
logistics constraints that may affect the procurement and construction effort. 

Engineering, Procurement and Construction Management Approach  

Two  engineering,  procurement  and  construction  management  (“EPCM”)  strategies  have  been  identified  that  are 
structured to account for the abnormally long pre-strip mining operation. The first option is the basis for the capital and 
operating cost estimate. 

Early Engineering Only with 2-Stage Procurement 

There is a need to establish the mine facilities and assemble the Mine Fleet in time to allow the pre-strip operation to 
start some two years before the Process Plant receives its first ore. This means that there will be a significant amount of 
detailed  engineering  requiring  completion  well  in  advance  of  the  time  required  for  conventional  engineering, 
procurement  and  construction  of  just  the  process  plant  and  supporting  infrastructure.  This  has  been  assessed  as 
requiring detailed engineering to start some four years before the process plant starts production. 

In particular, the pioneer access road design and contracts and civil design for the Mine Support facilities will be required 
early in the schedule. By default, the rest of the civil design would need to attach to that early works for simple plant 
layout and construction coordination purposes. For that to occur the plant layout will be required to be established at 
an early stage. That in turn is dependent on sizing and selection of the major process equipment items and the receipt 
of vendor data to complete the plant layout. 

Effectively, the detailed design phase will need to follow the conventional approach and run its course but started at a 
time  that  meets  the  early  works  schedule  requirements.  Everything  other  than  the  mine  support  facilities  will  be 
designed some two years in advance of when it is needed. 

With the early equipment order placement, the supply phase could become inordinately long, extending over three years 
in most cases, when in fact the equipment is not likely to be needed until the last eighteen months prior to plant start¬up. 

An  unorthodox  but  proven  option  to  this  extended  design,  supply  and  construction  schedule  is  to  have  the  EPCM 
Contractor procure the major equipment in two steps: 

60 

• 

• 

Step  1:  Procure  only  the  vendor  certified  engineering  data  to  allow  detailed  engineering  to  continue  to 
completion but hold the manufacturing functions until later in the overall schedule, effectively a delay of around 
twelve to fifteen months. 

Step  2:  Based  on  agreed  vendor  manufacturing  durations,  apply  a  “late”  release  of  the  equipment  for 
manufacture with deliveries effectively becoming a “Just-in Time” logistics operation. 

This strategy provides the following advantages: 

• 

• 

• 

• 

• 

Engineering can start and continue to completion using critical certified vendor data without the need for an 
extended “standby” involvement. 

Procurement functions can work in parallel with the engineering group with no disconnect between  the two 
disciplines. 

The procurement team can generally disband early in the schedule with just key personnel retained to provide 
continuity of support. 

The  expediting  team  can  mobilize  later  in  the  schedule  to  drive  manufacture  and  delivery  in  a  concerted 
campaign. 

Equipment deliveries can be orchestrated to suit the conditions at the time with everything consolidated into a 
transit compound for coordinated shipping to site. 

•  Reduced cashflow demands.  

Potential issues to be mitigated with this approach are: 

• 

The vendors need to be clearly briefed as to what the system means to their manufacturing schedule. 

•  A payments formula needs to be in place to account for a delayed delivery strategy. 

• 

Some vendors have difficulty in determining just what their actual engineering costs are.  

Early EPCM Leading to Plant Care and Maintenance  

Under this approach, the EPCM would work to conventional design and construction schedule, starting to suit the mine 
access requirements but following on to completion without interruption. That would bring the total process plant and 
supporting infrastructure to a mechanical completion condition nominally twelve to fifteen months before it is able to 
start work. 

The plant could not be commissioned through lack of ore and would have to be placed into care and maintenance mode 
until ore became available. This has an inherent advantage in that if the pre-strip operation was completed earlier than 
scheduled, and sufficient water is accumulated, the plant operations would be able to take advantage of the fact the 
plant was already mechanically complete. The care and maintenance requirements in that environment for that duration 
will require close assessment. 

Interpretations and Conclusions 

The Arctic deposit will be mined at an maximum annual rate of 35 Mt of ore per year with an overall stripping ratio of 
7.3. Ore will be processed by conventional methods to annually produce 234 kt of copper, 23 kt of lead, and 174 kt of 
zinc, all in concentrates for provision to third party refiners. Waste and tailings materials will be stored in surface facilities, 
which  will  be  closed  and  reclaimed  at  the  end  of  the  mine;  contact  water  will  be  treated  and  discharged  to  the 
environment throughout the life of mine. Precious metals attendant with the concentrates will be largely payable. While 

61 

there  are  deleterious  elements  reporting  to  the  concentrates  at  levels  that  could  incur  penalties,  special  processing 
provisions have been included in the flowsheet to make a readily saleable concentrate. 

In terms of project execution, the mine requires nominally two years of pre-strip operations, tailings pond starter dam 
development and water accumulation before actual production mining operations can commence. 

For that pre-strip work to start, the Arctic access road from the Ambler Access Project intersection to the mine site will 
have to be constructed to at least a pioneer road condition that will allow the mine fleet and the support facilities to be 
delivered, built, and made operational. 

Based on $1,177 million of initial capital costs, sustaining capital costs of $114 million, closure costs of $428 million, 
$2,969 million in LOM off-site operating costs and $2,794 million in LOM on-site operating costs, pre-tax financial results 
show a project IRR of 25.8% and an NPV of $1,500 million at an 8% discount rate and a 2.9-year payback period. Post-tax 
results show a project IRR of 22.8% and NPV of $1,108 million at an 8% discount rate and a 3.1-year payback period. 

Bornite Project 

The Company is subject to and required to disclose mineral resources and mineral reserves in accordance with S-K 1300. 
While the S-K 1300 rules are similar to NI 43-101 rules in Canada, they are not identical and therefore two reports have 
been produced for the Arctic Project. The information in Item 2, Properties, contains pertinent  information required 
under both NI 43-101 and S-K 1300. 

Except as otherwise stated, the scientific and technical information relating to the Bornite Project contained in this Form 
10-K is derived from the (i) 2023 S-K 1300 report for Bornite titled “Technical Report Summary on the Initial Assessment 
of the Bornite Mineral Resource, Northwest, Alaska, USA” dated November 30, 2022 prepared by Wood Canada Limited, 
which is unaffiliated with Trilogy  (“S-K 1300 Bornite Report”) and the (ii) technical report titled “NI 43-101 Technical 
Report on the Mineral Resource Update of the Bornite Project, Northwest Alaska, USA” with an effective date of January 
26, 2023, prepared by Wood Canada Limited (the “NI 43-101 Bornite Report”). The information regarding the Bornite 
Project is based on assumptions, qualifications and procedures which are not fully described herein. Reference should 
be  made  to  the  full  text  of  the  S-K  1300  Bornite  Report  and  the  NI  43-101  Bornite  Report  which  has  been  filed,  as 
applicable, with certain Canadian securities regulatory authorities pursuant to NI 43-101.  The NI 43-101 Bornite Report 
is available for review on SEDAR at www.sedar.com and the S-K 1300 Bornite Report is available for review on EDGAR at 
www.sec.gov. 

Property Description, Location, and Access 

The Bornite property is located in the Ambler Mining District of the southern Brooks Range in the NWAB of Alaska. The 
property is located in Ambler River A-2 quadrangle, Kateel River Meridian T 19N, R 9E, sections 4, 5, 8 and 9. The Bornite 
Project is located 248 km east of the town of Kotzebue, 19 km north of the village of Kobuk, 275 km west of the Dalton 
Highway  (an  all-weather  state  maintained  public  road)  at  geographic  coordinates  N67.07°  latitude  and  W156.94° 
longitude (Universal Transverse Mercator North American Datum 83, Zone 4W coordinates 7440449N, 589811E). 

62 

Primary  access  to  the  Bornite  Project  is  by  air,  using  both  fixed  wing  aircraft  and  helicopters.  There  are  four  well 
maintained, approximately 1,500 m-long gravel airstrips located near the property, capable of accommodating charter 
fixed wing aircraft. These airstrips are located 40 km west at Ambler, 23 km southwest  at Shungnak, 19 km south at 
Kobuk, and 15 km south at Dahl Creek. There is daily commercial air service from Kotzebue to the village of Kobuk, the 
closest community to the property. During the summer months, the Dahl Creek airstrip is suitable for larger aircraft, such 
as C-130 and DC-6. 

There is also a  700 m airstrip located at the Bornite camp. The airstrip at Bornite is suited to smaller aircraft, which 
support the Bornite camp with personnel and supplies. 

A two-lane, two-wheel drive gravel road links the Bornite camp to the 1,525 m Dahl Creek airstrip and village of Kobuk. 

On February 11, 2020, Trilogy Metals transferred the UKMP, including the Bornite property, to a 50/50 joint venture 
named Ambler Metals. With NANA’s approval, Trilogy Metals also contributed, along with the UKMP, its rights under the 
NANA  Agreement  to  Ambler  Metals  while  its  joint  venture  partner,  South32,  contributed  $145  million  dedicated  to 
advancing the projects. 

The  NANA  Agreement  provides  that  NANA  will  grant  Trilogy  Metals  the  nonexclusive  right  to  enter  onto,  and  the 
exclusive right  to explore, the Bornite Lands and the ANCSA Lands (each as defined in the NANA Agreement) and in 
connection therewith, to construct and utilize temporary access roads, camps, airstrips, and other incidental works.  The 
NANA Agreement has a term of 20 years, with an option in favour of Trilogy Metals to extend the term for an additional 
10 years.  The NANA Agreement may be terminated by mutual agreement of the parties or by NANA if Trilogy Metals 
does not meet requirements of aggregate expenditures over two consecutive calendar years are not at least $600,000 
on NANA’s lands.  Trilogy Metals has confirmed they met this expenditure requirement to date. 

The  NANA  Agreement  outlines  a  partnership  agreement  for  the  development  the  UKMP.    If,  following  receipt  of  a 
feasibility study and the release for public comment of a related draft environmental impact statement, Ambler Metals 
decides to proceed with construction of a mine on the lands subject to the NANA Agreement, Ambler Metals will notify 
NANA in writing and NANA will have 120 days to elect to either (a) exercise a non-transferrable back-in-right to acquire 
between 16% and 25% (as specified by NANA) of that specific project; or (b) not exercise its back-in-right, and instead 
receive a net proceeds royalty equal to 15% of the net proceeds realized by Ambler Metals from such project. The cost 
to exercise such back-in-right is equal to the percentage interest in the property multiplied by the difference between (i) 
all costs incurred by Ambler Metals or its affiliates on the property, including historical costs incurred prior to the date 
of the NANA Agreement together with interest on the historical costs; and (ii) $40 million (subject to exceptions). This 
amount will be payable by NANA to Ambler Metals in cash at the time the parties enter into a joint venture agreement 
and in no event will the amount be less than zero. 

63 

 
In the event that NANA elects to exercise its back-in-right, the parties will, as soon as reasonably practicable, form a joint 
venture with NANA electing to participate between 16% to 25%, and Ambler Metals will own the balance of interest in 
the joint venture.  Upon formation of the joint venture, the joint venture will assume all obligations of Ambler Metals 
and  be  entitled  to  all  the  benefits  of  Ambler  Metals  under  the  NANA  Agreement  in  connection  with  the  mine  to  be 
developed and the related lands.  A party’s failure to pay its proportionate share of costs in connection with the joint 
venture will result in dilution of its interest.  Each party will have a right of first refusal over any proposed transfer of the 
other party’s interest in the joint venture other than to an affiliate or for the purposes of granting security.  A transfer 
by either party of a  NSR royalty on the property or any net  proceeds royalty interest  in the property other than for 
financing purposes will also be subject to a first right of refusal. 

In connection with possible development on the Bornite Lands, Ambler Metals and NANA will execute a mining lease to 
allow Ambler Metals or the joint venture to construct and operate a mine on the Bornite Lands.  These leases will provide 
NANA a 2% NSR royalty as to production from the Bornite Lands. 

If Ambler Metals decides to proceed with construction of a mine on its own lands subject to the NANA Agreement, NANA 
will enter into a surface-use agreement with Ambler Metals which will afford Ambler Metals access to the project along 
routes approved by NANA. In consideration for the grant of such surface use rights, Ambler Metals will grant NANA a 1% 
NSR royalty on production and an annual payment of $755 per acre (as adjusted for inflation each year beginning with 
the second anniversary of the effective date of the NANA Agreement and for each of the first 400 acres (and $100 for 
each additional acre) of the lands owned by NANA and used for access which are disturbed and not reclaimed. 

Environmental Liabilities 

Under the NANA Agreement, NANA is required to complete a baseline environmental report following the cleanup of 
the former mining camp on the Bornite Lands; this work must be completed to Alaska Department of Environmental 
Conservation  standards.  Cleanup  includes  the  removal  and  disposal,  as  required  by  law,  of  all  hazardous  substances 
present on the Bornite Lands. NANA has indemnified and will hold Trilogy Metals harmless for any loss, cost, expense, 
or  damage  suffered  or  incurred  attributable  to  the  environmental  condition  of  the  Bornite  Lands  at  the  date  of  the 
baseline report which relate to any activities prior to the date of the agreement.  

Reclamation of mineral exploration activities at the Bornite property is completed under the guidelines presented by the 
State of Alaska in the Multi-Year Hardrock Exploration Permit  #2183 issued by the Department  of Natural Resources 
Division of Mining, Land, and Water.  

Permits 

Multiple permits are required during the exploration phase of the Bornite property. Permits are issued from Federal, 
State, and Regional agencies, including: the Environmental Protection Agency, US Army Corps of Engineers, ADEC, Alaska 
Department of Fish and Game, ADNR, and NWAB.  The State of Alaska permit for exploration on the Bornite property, 
known as the Annual Hardrock Exploration Activity (“AHEA”) Permit, is obtained and renewed every five years through 
the ADNR – Division of Mining, Land and Water. Trilogy Metals held an AHEA exploration permit in good standing with 
the ADNR and has done so each year since 2004 under Alaska Gold.  The Bornite property is within the NWAB therefore 
requiring  a  Title  9  Miscellaneous  Land  Use  permit  for  mineral  exploration,  fuel  storage,  gravel  extraction,  and  the 
operation of a landfill.  The Bornite camp, Bornite landfill, and Dahl Creek camp are permitted by the ADEC.  After the 
formation of the joint  venture, Ambler Metals has renewed the necessary permits for exploration and related camp 
operations. 

As  the  Bornite  Project  progresses,  additional  permits  for  environmental  baseline  and  engineering  studies  will  be 
necessary at Federal, State, and Regional levels. 

The QP is not aware of any significant factors and risks that may affect access, title, or the right or ability to perform work 
on the Bornite property other than what is described in the NI 43-101 Bornite Report and the S-K 1300 Bornite Report. 

64 

The mineral resource estimates with respect to the Bornite Project are reported on a 100% basis, of which Trilogy’s share 
is 50%. 

History 

Kennecott and Bear Creek Mining Tenure 

Prospectors in search of gold, travelling up the Kobuk River in 1898 to 1899 found several small gold placer deposits in 
the  southern  Cosmos  Hills  that  were  worked  intermittently  over  the  ensuing  decades.  Around  this  time,  copper 
mineralization at Ruby Creek and Pardner Hill was explored using small shafts and adits. At Ruby Creek, Smith describes 
bornite and chalcopyrite and lesser amounts of galena and pyrite filling open spaces in brecciated zones in limestone 
and in places replacing dolomite breccia. 

In 1947, Rhinehart “Rhiny” Berg staked claims over the Ruby Creek prospects, carried out extensive trenching and the 
first  diamond  drilling,  and  constructed  an  airstrip  for  access.    In  1957,  BCMC,  Kennecott’s  exploration  subsidiary, 
optioned the property from Berg.Exploration drilling in 1961 and 1962 culminated in the discovery of the “No.1 Ore 
Body” where drill hole RC-34 cut 20 m of 24% Cu (the “No. 1 Ore Body” is a historical term used by BCMC that does not 
connote economic viability in the present context; it is convenient to continue to use the term to describe exploration 
work in a specific area that was previously referred to as the Ruby Creek Zone and is now referred to as simply the Ruby 
Zone).  The discovery of the “No. 1 Ore Body” led to the development of an exploration shaft in 1965 through 1966, the 
development  of an exploration drift  and the completion of underground drilling in 1967. The discovery of the Arctic 
project in 1965 prompted a hiatus in exploration at Bornite, and only limited drilling occurred up until 1997. 

In the late 1990s, Kennecott resumed its evaluation of the Bornite deposit and the mineralization in the Cosmos Hills 
with  an  intensive  soil,  stream,  and  rock  chip  geochemical  sampling  program  using  a  32-element  inductively  couple 
plasma (“ICP”) analyses. Grid soil sampling yielded 765 samples. Ridge and spur sampling resulted in an additional 850 
soil  samples  in  the  following  year.  Skeletonized  core  samples  (85  samples)  from  key  historical  drill  holes  were  also 
analyzed using 32 element ICP analytical methods. Geochemical sampling identified multiple areas of elevated copper 
and zinc in the Bornite region. 

Kennecott  completed  numerous  geophysical  surveys  as  an  integral  part  of  exploration  throughout  its  tenure  on  the 
Bornite property. Various reports, notes, figures, and data files stored in Kennecott’s Salt Lake City exploration office 
indicated that geophysical work included, but was not limited to, the following: 

•  Airborne magnetic and EM surveys (fixed-wing INPUT) (1950s) 

•  Gravity,  single  point,  audio-frequency  magnetotelluric,  EM,  borehole  and  surface  induced  polarization 

(“IP”)/resistivity surveys (1960s) 

•  Gravity, airborne magnetic, and controlled-source audio-frequency surveys (1990s). 

We have minimal information or documentation associated with these geophysical surveys conducted prior to the 1990s. 
Where data are available in these earlier surveys, the lack of details in data acquisition, coordinate systems, and data 
reduction procedures limit their usefulness. The only complete geophysical report that is available concerns down-hole 
IP/resistivity results. Most notable is the 1996 Bouguer gravity survey from the Bornite deposit into the Ambler Lowlands. 
The Bornite deposit itself is seen as a significant 3 milligal anomaly. Numerous 2 milligal to > 6 milligal anomalies occur 
under cover in the Ambler Lowlands and near the Aurora Mountain and Pardner Hill occurrences. In addition to the 
geophysical surveys conducted by Kennecott, the ADNR completed an aeromagnetic survey of portions of the Ambler 
mining district in 1974-1975. 

Several studies have been undertaken reviewing the geology and geochemistry of the Bornite deposit. Most notable is 
Murray  Hitzman’s  PhD  dissertation  at  Stanford  University  and  Don  Runnel’s  PhD  dissertation  at  Harvard  University. 
Bernstein and Cox reported on mineralization of the “No. 1 Ore Body” in a 1986 paper in Economic Geology. In addition 

65 

to the historical work, Ty Connor at the Colorado School of Mines recently completed a Master’s thesis which reported 
on the timing of alteration and mineralization at the Bornite deposit. 

Kennecott conducted two technical reviews of the groundwater conditions and a summary of the findings related to the 
flooding of the exploration shaft. In 1961, Kennecott collected 32 coarse reject samples from five drill holes to support 
preliminary  metallurgical  test  work  at  Bornite.  Samples  targeted  high-grade  (>  10%)  copper  mineralization  from  the 
Upper Reef at the Ruby Zone. 

Geological Setting, Mineralization and Deposit Types 

Geology 

The Bornite Project is located within the Arctic Alaska Terrane, a sequence of mostly Paleozoic continental margin rocks 
that  make  up  the  Brooks  Range  and  North  Slope  of  Alaska.  It  is  within  the  Phyllite  Belt  geologic  subdivision,  which 
together with the higher-metamorphic grade Schist Belt, stretches almost the entire length of the southern Brooks Range 
and  is  considered  to  represent  the  hinterland  of  the Jura-Cretaceous  Brookian  orogeny.  The  southern  margin  of  the 
Phyllite Belt is marked by mélange and low-angle faults associated with the Kobuk River fault zone, while the northern 
boundary is thought to be gradational with the higher-grade metamorphic rocks of the Schist Belt. 

The  geology  of  the  Bornite  resource  area  is  composed  of  alternating  inervals  of  carbonate  rocks  (limestone  and 
dolostone) and calcareous phyllite. Limestone transitions laterally  into dolostone near zones of mineralization and is 
considered hydrothermally altered. Spatial relationships and petrographic work suggest that dolomitization is genetically 
related to early stages of the copper mineralizing system; however, recent re-logging has questioned this view. 

In 2015, Trilogy tried to improve the understanding of the distribution and nature of the various lithologic units and their 
context within a sedimentary depositional model. A new interpretation, based on lithogeochemical signatures of the 
various  units  along  with  their  historical  visual  logging,  concluded  that  stacked  debris  flows  composed  of  basal  non-
argillaceous channelized breccias were overlain by upward fining upward sequence of increasingly argillaceous breccias 
capped by high calcium (Ca) phyllites, confined laterally in channels between either massive or thin-bedded platform 
carbonates. 

Two mineralized stacked debrite successions were named the Lower and Upper Reefs. The Upper Reef grades upward 
into  argillaceous  limestones  instead  of  discrete  high  Ca  phyllites  indicating  a  waning  of  debris  supply.  Based  on  this 
interpretation, a  series of individual debrites were identified and modeled. In contrast to the locally  derived high-Ca 
phyllites  of  the  debrite-dominated  Bornite  carbonate  sequence,  low  calcium  (Ca)  phyllites  are  abundant  in  the 
allochthonous  Anirak  schist  (quartz  phyllite)  and  the  Beaver  Creek  phyllite  that  underlie  and  overlie  the  Bornite 
carbonate sequence, respectively. In addition to depositional lithostratigraphy, a cross-cutting mineralized breccia called 
the P-Breccia has been identified in and around the South Reef deposit. Though poorly defined due to lack of drilling in 
the area, the P-Breccia zone—which contains excellent copper grade—lies at the apex of the Iron Mountain discontinuity. 
Although  clearly  post-deformational,  it  remains  unclear  whether  the  P-Breccia  is  a  post-depositional  structural, 
hydrothermal or solution-collapse breccia. 

A short lithostratigraphic project carried out during the 2021 field season updated the interpretation of the depositional 
environment  of  the  Bornite  succession;  this  resulted  in  significant  differences  when  compared  to  the  previously 
summarized interpretations. The Bornite succession is now understood to be a carbonate slope deposit characterized by 
(a) lime mudstone, exported to the slope from a contemporaneous shallow-marine carbonate factory, variably mixed 
with and interlayered with (b) background argillaceous sediment that is locally carbonaceous. Superimposed on these 
calcite-dominated normal slope strata are locally impressive thicknesses of dolomudstone-clast conglomerate (formerly 
breccia).  Slope  limestone  and  siltstone-mudstone  were  originally  centimetrically  to  decimetrically  bedded,  but  are 
commonly ductilely deformed, producing the variably limey phyllites that exhibit sub-mm scale foliation. In contrast, the 
dolostone-clast conglomerates and individual dolomudstone clasts responded brittlely to Brookian stress and show no 

66 

significant shearing or plastic deformation. Instead, plastic deformation is largely restricted to the various phyllitic layers 
around the peripheries of the dolostone bodies. 

Structural  fabrics  observed  on  the  Bornite  property  include  rare  bedding  and  two  distinct  metamorphic  foliations. 
Bedding (S0) can be measured only rarely where phyllite and carbonate are interbedded and it is unclear to what extent 
it is transposed. The pervasive foliation (S1) is often mylonitic and exhibits both an imprinted stretching lineation and 
preferred  top  direction.  It  is  easily  measured  in  phyllites  and  is  commonly  reflected  by  colour  banding  and/or 
stylolamination  (flaggy  habit  in  outcrop)  of  the  carbonates.  Some  limestone  outcrops,  in  particular  the  thin  bedded 
limestone on Aurora Mountain and the marbles at the base of Coral Hill, also exhibit a stretching lineation. Core-logging 
shows that S1 is folded gently on a 10 m scale and locally tightly folded at the decimetre scale forming a common S2 axial 
planar cleavage. S2 is folded gently on a 10 m scale forming an upright mesoscale S3 foliation. S1 and S3 foliations are 
thought to be Jura-Cretaceous in age. 

Structural mapping in 2021 recognized a well-developed stretching lineation (i.e., L-tectonite) in the carbonate-phyllite 
rocks, typically oriented shallowly towards the north-northeast or south-southwest. Top directions indicate movement 
to the south or south-southwest along the vector of the stretching lineation. Moreover, new mapping indicates that stiff 
Bornite  rocks,  in  particular  metric  to  hectametric  dolostone  bodies,  have  been  boudinaged  into  3D  ellipsoids.  Slip  is 
accommodated by phyllites. Interpretation of this mapping should be performed to determine whether such a tectonic 
style plays a role in the distribution of copper mineralization. 

Owing to their greater rigidity, dolostone bodies of secondary dolostone manifest strain differently: tan hydrothermal 
dolostone tends to be broken into centimetre- to decimetre-scale blocks, whereas grey (diagenetic?) dolostone may 
exhibit unusual, contorted forms, some resembling human fingers or swan necks, as evident in outcrop. Dolostone is 
rarely cut by plastically deformed zones and instead forms metric to hectametric lenses (augens) encased in plastically 
deformed  calc-mylonite  and  calc-phyllite.  This  deformation,  presumably  a  product  of  the  Jura-Cretaceous  Brookian 
orogeny, complicates sedimentological interpretations. 

Mineralization  at  Bornite  forms  tabular  mineralized  zones  that  coalesce  into  crudely  stratabound  bodies  hosted  in 
dolostone conglomerate/breccia. Two significant  dolomitic horizons that host  mineralization have been identified by 
drilling and include: 1) the Lower Reef, a substantial 100 m to 300 m thick dolomitized zone lying immediately above the 
basal quartz phyllite unit of the Anirak schist and 2) the Upper Reef, a 100 m to 150 m thick dolomite horizon that sits 
roughly 300 m higher in the section. The Lower Reef is separated from the Upper Reef by a zone of ductilely sheared 
phyllites up to 60 m thick. 

The Lower Reef dolostone outcrops along the southern margin of the Ruby Zone and is spatially extensive throughout 
the deposit area. It hosts a significant portion of the shallow mineral resources in the Ruby Zone as well as higher grade 
mineral resources down-dip and to the northeast in the South Reef area. The Upper Reef hosts relatively high-grade 
mineral resources to the north in the Ruby Zone. The Upper Reef appears to lie at an important northeast-trending facies 
transition  to  the  northwest  of  the  main  drilled  area  and  appears  to  be  at  least  partially  thrust  over  the  Lower  Reef 
stratigraphy to the southeast. 

Drill results from 2013 show dolomitization and copper mineralization in the Upper and Lower Reefs coalescing into a 
single unit along the northern limits of current exploration. The northeast- trending Ruby Zone and South Reef areas also 
coalesce into a roughly 1,000 m wide zone of >200 m thick dolomite containing significant copper mineralization dipping 
north at roughly 5 to 10°. The 2017 drill results show that the mineralized dolomite interval continues for at least another 
700m down-dip to the northeast from mineralization in the Upper and Lower Reefs. 

Mineralization 

Copper  mineralization  at  Bornite  comprises  chalcopyrite,  bornite,  and  chalcocite  distributed  in  stacked,  stratabound 
zones exploiting favourable lithologies (conglomerate/berccia) within the Bornite sequence. Mineralization occurs, in 
order  of  increasing  grade,  as  disseminations,  irregular  and  discontinuous  stringer-style  veining,  breccia  matrix 

67 

replacement, and stratabound massive sulphides. The distribution of copper minerals is zoned around the bottom-centre 
of  each  zone  of  mineralization,  with  bornite-chalcocite-chalcopyrite  at  the  core  progressing  outward  to  a  fringe  of 
chalcopyrite-pyrite. Additional volumetrically minor copper minerals include carrollite, digenite, tennantite-tetrahedrite, 
and  covellite.  Stringer  pyrite  and  locally  significant  sphalerite  occur  above  and  around  the  copper  zones  and  locally 
massive pyrite and sparse pyrrhotite are associated with siderite alteration below copper mineralization in the Lower 
Reef. 

Significant cobalt mineralization is found accompanying bornite-chalcocite mineralization. Cobalt often occurs with high-
grade  copper  as  carrollite  (Co2CuS4)  and  as  cobaltiferous  rims  on  recrystallized  pyrite  grains.  Preliminary 
geometallurgical work by Trilogy showed that cobalt occurs primarily as cobaltiferious pyrite (approximately 80% of the 
contained cobalt) and within other cobalt minerals such as carrollite, and cobaltite (CoAsS). 

Some appreciable silver values are also found at Bornite, particularly in association with bornite-rich mineralization in 
the South Reef area and Ruby Zone. 

Deposit Type 

Copper-cobalt-silver-zinc mineralization at Bornite forms disseminations, veins, and massive sulphides in stacked, semi-
stratabound  bodies  closely  associated  with  secondary  hydrothermal  dolomitization.  The  cross-cutting  nature  of  the 
mineralization along with the presence of early pyrite and sphalerite in sedimentary breccia clasts suggest an epigenetic 
origin that was temporally very close after the deposition of host strata. Re-Os dating supports this interpretation. 

Data are limited regarding the sources and nature of the copper-rich fluids that formed the Bornite deposit, but they 
suggest that mineralizing fluids may have formed from the interaction of saline basin fluids with mafic volcanic rocks in 
the area. 

An early epigenetic carbonate-hosted Cu-Co model is applicable for exploration targeting in the project area. 

Exploration 

Exploration work completed by Kennecott is summarized above. In addition to the extensive drilling completed during 
the  more  than  40-year  tenure  of  Kennecott  in  the  district,  Kennecott  completed  widespread  surface  geochemical 
sampling,  regional  and  property  scale  mapping,  and  numerous  geophysical  surveys  employing  a  wide  variety  of 
techniques. Most of this data has been acquired by us and forms the basis for renewed exploration that targets Bornite-
style mineralization in the Bornite carbonate sequence. 

2006 NOVAGOLD 

In 2006, NOVAGOLD contracted Fugro Airborne Surveys to complete a detailed helicopter DIGHEM (frequency-domain 
EM), magnetic and radiometric survey of the Cosmos Hills. The survey covered a rectangular block approximately 18 km 
by 49 km which totalled 2,852-line km. The survey was flown at 300 m line spacing with a line direction of N20E. The 
DIGHEM helicopter survey system produced detailed profile data of magnetics, EM responses and radiometrics (total 
count,  uranium,  thorium,  and  potassium)  and  was  processed  into  maps  of  magnetics,  discrete  EM  anomalies,  EM 
apparent resistivity, and radiometric responses. 

2010 NOVAGOLD 

In 2010, in anticipation of completing the NANA Agreement, NANA granted NOVAGOLD permission to begin low level 
exploration at Bornite. This consisted of re-logging and re-analyzing select drill holes using a NitonTM portable XRF. In 
addition to the 2010 re-logging effort, NOVAGOLD contracted a consulting geophysicist to compile a unified airborne 
magnetic map for the Ambler mining district from Kennecott, Alaska DNR, and NOVAGOLD airborne geophysical surveys. 

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2011 NOVAGOLD 

In  2011,  NOVAGOLD  contracted  Zonge  International  Inc.  (“Zonge”)  to  conduct  both  dipole-dipole  complex  resistivity 
induced polarization (“CRIP”) and natural source audio-magnetotelluric (“NSAMT”) surveys over the northern end of 
Bornite to develop tools for additional exploration targeting under cover to the north. 

NSAMT data were acquired along two lines totaling 5.15 line-km; one line is oriented generally north-south through the 
centre  of  the  survey  area  and  the  other  line  is  the  southernmost  east-west  line  in  the  survey  area.  CRIP  data  were 
acquired on five lines: four east-west lines and one north-south line, for a total coverage of 14.1 line-km and 79 collected 
CRIP stations. The initial objective of the survey was to investigate geological structures and the distribution of sulphides 
possibly associated with copper mineralization. 

Results from the paired surveys show that wide-spaced dipole-dipole resistivity is the most effective technique to directly 
target the mineralization package. Broad, low-resistivity anomalies reflecting pyrite haloes and mineralization appear to 
define the limits of the fluid package. Well-defined and often very strong chargeability anomalies are also present but 
appear in part  to be masked by phyllitic units which  also have strong chargeability signatures. NSAMT shows similar 
resistivity features as the IP, but these are less well resolved. 

2012 NovaCopper 

Considering  the  success  of  the  2011  geophysical  program,  we  contracted  Zonge  to  conduct  a  major  district-wide 
dipole/dipole IP survey, a down-hole IP radial array survey in the South Reef area, and an extensive physical property 
characterization study of the various lithologies to better interpret the existing historical geophysical data. 

Zonge completed 48 line-km of 200 m dipole/dipole IP during 2012, infilling and expanding on the 2011 survey, and 
stretching across the most prospective part of the outcropping permissive Bornite carbonate sequence. The results show 
a  well-defined  low  resistivity  area  associated  with  mineralization  and  variable  IP  signatures  attributed  both  to 
mineralization and the overlying Beaver Creek phyllite. Numerous target areas occur in the immediate Bornite area with 
lesser targets occurring in the Aurora Mountain and Pardner Hill areas and in the far east of the survey area. During the 
2012 drill program at South Reef, a single drill hole was targeted on a low resistivity area approximately 500 m to 600 m 
southeast of the South Reef mineralization trend. Although the drill hole intersected some dolomite alteration in the 
appropriate stratigraphy, no significant sulphides were encountered. 

In addition to the extensive ground IP survey, Zonge also completed 9 km of down-hole radial IP using an electrode 
placed  in  drill  hole  RC12-0197  to  further  delineate  the  trend  and  potential  in  and  around  the  South  Reef.  Extensive 
physical property data including resistivity, chargeability, specific gravity, and magnetic susceptibility were captured for 
use in modelling the existing ground IP and gravity surveys, and the airborne EM and magnetic surveys. 

In addition to geophysical focused exploration, a district wide geologic map was compiled integrating Kennecott’s 1970’s 
mapping of the Cosmos Hills with selective Trilogy mapping in 2012. 

2013 NovaCopper 

The emphasis of the 2013 program was to further validate and refine the 2012 geologic map of the Cosmos Hills. A deep 
penetrating  soil  and  vegetation  geochemical  orientation  survey  was  completed  over  the  South  Reef  deposit,  using 
various partial leaches and pH methods. The initial, approximately 1 km, test lines suggest a good response for several 
of the partial leaches of the soils but little response in the vegetative samples. Follow-up is warranted to the north of the 
deposit into the Ambler Lowlands. 

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2014 NovaCopper 

During 2014, exploration work was limited to a re-logging and re-sampling program of historical Kennecott drill core. 

2015 NovaCopper 

As a follow-up to the 2013 field program, a deep penetrating soil and vegetation geochemical survey was extended north 
of  the  deposit  into  the  Ambler  Lowlands.  Trilogy  geologists  completed  a  litho-geochemical  desktop  study  and  a 
comprehensive update to the 3D lithology model. 

2017 Trilogy 

The 2017 field program extended the 2013 and 2015 deep penetrating geochemical (“DPG”) soil survey another 500m 
to the northeast. The 2013 soil line was extended 1,500m to the east to test over the covered projection of the Two Grey 
Hills carbonate section. The 3D lithology model was updated to incorporate the 2017 drill program results. 

Trilogy also completed a close spaced ground gravity survey over a 2 km by 4km grid with 100 m station spacing over the 
resource area  and extending  northeast  over the 2017 drill target  area.  The complete  Bouguer anomaly residual plot 
(removes  a  strong  decreasing  to  the  northeast  regional  gradient)  shows  good  correlation  with  the  Lower  Reef 
mineralization that outcrops on surface with the gravity high gradually decreasing down-dip to the northeast. 

As part  of the overall  gravity program, Mira  Geosciences  created a  petrophysical model for the Bornite deposit  that 
synthesized the expected gravity response on surface (forward model) for the 2017 gravity stations. This forward model 
matches very closely with the actual survey data over the deposit area but diverges on the south end where the expected 
response of gravity low is actually a strong gravity high that may reflect shallow mineralization up-dip along the South 
Reef  trend.  Mira  also  completed  a  geologically  constrained  3D  inversion  using  the  2017  gravity  data.  Two  areas  of 
anomalously high densities (>2.9 g/cc) were identified. The first area extends up to 750m to the east-northeast of RC17-
0239, which was one of the more successful holes in 2017 and is coincident with the Iron Mountain structure. The second 
anomaly is located just above the Anirak contact (Lower Reef) to the west of the 2017 target area and 700m to the north 
of  the  closest  drill  hole  (RC-53),  which  is  weakly  mineralized  along  that  horizon.  This  area  falls  along  the northwest-
southeast high grade thickness trend. 

2018 Trilogy 

During the 2018 field season, Trilogy Metals carried out additional DPG and a 2D seismic survey at Bornite. In addition, 
geophysical and geochemical data from Bornite were studied using existing datasets. Soil sampling was completed on 
the westerly extension of the DPG lines on the northwestern portion of the Bornite deposit. DPG was used to assist with 
outlining the edges of the deposit as well as to corroborate gravity anomalies defined during the 2017 field season. 

A  2D  seismic  survey  was  completed  by  HiSeis  (3D  seismic  imaging)  in  June  2018.  This  2D  acquisition  program  was 
designed to test whether seismic reflection was suitable for the Bornite deposit and to understand the logistics of any 
future 3D seismic survey over the project area. Two 6 km 2D seismic lines, a dip line and a strike line, were acquired with 
a total of 792 unique source locations to attempt to image hanging wall and footwall shears; other faults and shears; 
folding of stratigraphy; internal (within Bornite sequence) phyllite units; facies changes within the dolostones; and direct 
detection of massive sulphide mineralization; and any alteration associated with mineralization. Acquisition of this 2D 
dataset used 500 g seismic charges as a means of producing seismic energy. All seismic vibrations were measured on a 
fully active line of 1,189 geophone receivers which provided up to 6 km of offset on either side of the source using the 
Aries  I  seismic  acquisition  system.  Supporting  rock  property  data  were  acquired  from  drill  core  stored  in  Fairbanks, 
Alaska. 

Mira Geosciences completed a 3D inversion model of the 100 m spaced ground gravity data that were collected over the 
Bornite deposit during the 2017 exploration season. Using geology to constrain the model, three areas of anomalously 
higher gravity were defined. Unfortunately, none of these intervals were properly tested in 2017 with two holes, those 

70 

at  Anomaly  “B”  and  “C”,  ending  above  the  gravity  anomalies.  Two  of  the  three  identified  anomalies  from  the  2017 
inversion  modelling  changed  in  size  and  relative  orientation  with  the  updated  geologic  model.  Anomaly  B,  which 
stretches  to  the  northwest  from  hole  RC17-0238  decreased  in  extent,  likely  the  result  of  a  thicker-than-previously-
modelled Upper Reef carbonate section in RC17-0238. Anomaly C is much broader and less defined, indicating that it 
may be the result of underestimating the SG in the lithology model. This anomaly remains untested with the failures of 
drill  holes  RC17-0242  and  RC18-0245  and  should  be  redrilled  in  the  future.  Anomaly  A  is  relatively  unchanged  and 
remains coincident with the Iron Mountain structure. Holes RC18-0246, RC18-0249, and RC18-0250 tested the southwest 
edge of the anomaly where it joins the South Reef trend. Hole RC18-0250 suggests that mineralization wanes to the east, 
though this hole may have just missed mineralization controlled by the Iron Mountain structure. The northeast extent 
of this anomaly is still considered a viable exploration target. 

South32  completed  a  QAQC  review,  lithogeochemical-alteration  assessment,  and  a  vectoring/targeting  exercise  on 
downhole geochemical data on the Bornite deposit. The purpose of this exercise was to use downhole analyses to assess 
the geology, alteration, and mineralogy of the deposit to vector towards mineralization. The Bornite sequence can be 
classified into three geochemical groups including: 1) very low immobiles; 2) low immobiles; and 3) higher immobiles. 
The latter was then subdivided into five groups based on Al, Cr, and V concentrations. The very low and low immobile 
groups  are  predominately  limestones  and  dolomites  (including  breccias),  whereas  increasing  Al  in  higher  immobiles 
represent the increasingly argillaceous/micaceous units (phyllites). High Al samples in the lower Bornite sequence can 
be discriminated from those in the upper sequence based on high Ni:Cu ratios. In the South Reef area, lithogeochemistry, 
supported  Trilogy  Metals’  geologic  model,  identified  the  lower,  central  and  upper  Bornite  sequence  units  and 
distinguished many of the logged phyllites from breccias. The results support Trilogy Metals’ interpretation that the Ruby 
Zone in the Lower Reef is hosted in units corresponding to the South Reef central sequence. 

2019 Trilogy 

In 2019, Trilogy Metals contracted Geotech Ltd. (Geotech) of Aurora, Ontario  to complete VTEM Plus (versatile time 
domain  electromagnetic)  and  ZTEM  (z-axis  tipper  electromagnetic)  airborne  helicopter  geophysical  surveys  over  the 
Cosmos Hills and the Ambler VMS belt. Magnetics were measured using a cesium vapour sensor, while radiometrics was 
not collected due to snow cover. 

The VTEM survey was flown along 200 m spaced lines, oriented northwest-southeast over the entire Bornite carbonate 
sequence north of the Cosmos Arch (which hosts the Bornite deposit), with additional lines at 100 m spacing directly 
above the Bornite resource. A second set of perpendicular lines (southwest-northeast) were flown at 200 m spacing over 
just the general Bornite area. Tie lines at ~4,000 m spacing were flown perpendicular to the EM flight lines to provide 
control for the magnetic survey. 

The VTEM results from the Bornite sequence are complex and appear to be mostly reflecting bedrock lithologies (the 
graphitic phyllites). The conductive plates that were modelled are generally coincident with the interpreted phyllite units, 
as are the apparent anomalies tested by holes RC19-0263 and RC19-0266. 

2020 Ambler Metals 

Trilogy Metals and South32 decided not to proceed with the 2020 exploration program due to the coronavirus pandemic. 
The Bornite geologic model was updated using the 2019 drill program results. The Irish Centre for Research in Applied 
Geosciences  initiated  a  machine-learning  geochemical  modelling  project  to  help  define  the  controls  on  high-grade 
copper mineralization. 

2021 Ambler Metals 

During the 2021 field season, the understanding of the Bornite deposit and the potential for additional deposits was 
advanced with a new interpretation of the carbonate sequence at Bornite and an improved structural understanding of 
the  Cosmos  Hills.  A  specialist  in  carbonate  geology  from  Laurentian  University  re-logged  two  fences/sections  of  drill 
holes, east-west and north-south, through the Bornite deposit, to identify, distinguish and correlate lithofacies within 

71 

the Bornite sequence and to identify and distinguish different types/ages of dolomitization, including, if possible, their 
relation to mineralization. 

Turner describes the Bornite sequence as a tectonized normal carbonate slope deposit that consists of calcitic material 
(lime  mud)  derived  from  a  nearby  shallow-marine  source  area,  interlayered  with  variable  amounts  of  background 
terrigenous mud (argillaceous proportion increases with distance downslope). The observed sequence includes massive 
lime mudstone, thin-bedded argillaceous lime mudstone, lime mudstone centimetrically interbedded with terrigenous 
mudstone,  calcareous  siltstone,  and  limestone-clast  slope  conglomerates.  Brookian  deformation  strained  these 
argillaceous 
limestone  slope  deposits  to  varying  degrees  producing  phyllites  and  recrystallized,  strained 
limestones/marbles. 

Importantly, superimposed on the active limestone slope system is the local presence of dolostone-clast conglomerate. 
Dolostone clasts are equant and irregular; predominantly dolomudstone (locally with fossil fragments) and are likely 
derived from subaqueous horst blocks of pre-existing older dolostone and shed into the slope limestone system. The 
fault scarp(s) that shed dolostone clasts were probably part of a seafloor paleotopographic system that developed during 
regional extension and associated fault-mediated syn-depositional subsidence. 

Also initiated in 2021 was structural mapping around Pardner Hill and Aurora Mountain. Initial results indicate: (1) Large 
carbonate  bodies,  such  as  Pardner  Hill,  Shield  Mountain,  and  probably  also  Aurora  Mountain,  are  fault  klippen  in 
allochthonous  contact  with  the  structurally  subjacent  Anirak  schist;  (2)  Dolostone  bodies  are  typically  boudinaged 
forming metric to hectametric 3-D ellipsoids encased in ductilely deformed phyllites and, in some places, calc-mylonites 
(limestone protolith); (3) Top-South (to SSW) deformation at a number of outcrops in the Cosmos Hills suggest that this 
entire structural block may have been juxtaposed southward from the position of the Ambler Lowlands or, potentially, 
from off the top of the Ambler Highlands (Arctic area) during exhumation that was part of the Brookian orogeny; (4) the 
fault contact with the overlying Beaver Creek phyllite is likely a low-angle normal fault that cuts out of the Bornite deposit 
to the southeast where Beaver Creek is in structural contact with Anirak schist. 

Two  diamond  drill  holes  targeting  the  Bornite  copper-hosting  carbonate  sequence  in  the  Cosmos  Hills  and  Ambler 
Lowlands were completed during the 2021 field season.  Hole ALL21-001 targeted the northeast projection of the Bornite 
carbonate sequence under cover in the Ambler Lowlands about 7 km east-northeast of Bornite. The second hole, hole 
 Pardner Hill saddle, 3.5 km west  of the Bornite 
RC21-0267 was located at West  Bornite, along the Coxcomb Ridge 
deposit. 

Hole  ALL21-001  intercepted  alternating  units  of  limestone  clastic  breccia,  dolostone  clastic  breccia,  limestone  and 
dolostone with textures similar to the Beaver Creek carbonates; alternating intervals of argillaceous phyllite, argillaceous 
limey phyllite, argillaceous phyllitic limestone, and argillaceous limestone clastic breccias. The phyllitic units host trace 
pyrite mineralization and have geochemical signatures that are similar to Beaver Creek phyllites.  Unfortunately, the hole 
was lost at 335 m without drilling through the carbonate stratigraphy. 

Hole RC21-0267 tested the down-dip projection of weakly mineralized dolomitic breccia mapped in the saddle between 
Coxcomb Ridge and Pardner Hill. The hole intersected argillaceous phyllite (probable Beaver Creek) followed by Bornite 
sequence: alternating tan phyllitic limestone, tan limey phyllite, argillaceous/carbonaceous phyllitic limestone, limestone 
clastic breccia, limestone, and argillaceous limestone clastic breccias and dolostone clastic breccia. Trace to locally 1% 
chalcopyrite,  with  lesser  amounts  of sphalerite,  and  tennantite/tetrahedrite  occur  through-out  a  180  m  thickness  of 
dolostone clastic breccia, mostly as disseminations within the breccia matrix and in this carbonate veins. Within this zone 
a 54.9 m thick interval averages 0.165% Cu starting from 196.5 m. RC21-0267 ended in a quartz phyllite fault zone at 435 
m. 

Ambler Metals (2022) 

During  the  2022  field  season,  structural  mapping  around  Pardner  Hill  and  Aurora  Mountain  carried  out  in  2021  was 
extended to the south to Cosmos Mountain and to the east to Inerevuk Mountain. In addition, two holes were drilled, 

72 

hole RC22-0268 at Bornite West to follow up the mineralized interval encountered during the 2021 drilling, and the other 
at Pardner Hill, hole PH22-0180 to test the down-dip potential of the historical Pardner Hill resource to the south.  The 
results of these two holes are being compiled and interpreted. 

Drilling 

From 1957 to 2019, a total of 273 holes targeted the Bornite deposit during 24 different campaigns; 222 surface core 
holes and 51 underground core holes were drilled, totalling 106,406 m. All of the drill campaigns prior to 2011 were 
completed by Kennecott  or its exploration subsidiary, BCMC, and the drill campaigns  since 2011  were completed  by 
NovaGold (2011), NovaCopper (2012 and 2013) or Trilogy. 

In the summer of 2017, Trilogy Metals initiated eleven holes, but four were abandoned due to  drilling problems. The 
seven remaining drill holes stepped-out to the north for distances between 250 m to 400 m from the previous drill holes; 
these were distances considered too far to support the estimation of mineral resources at that time. 

In the summer of 2018, Trilogy Metals conducted a drilling program that included the completion of 12 holes that infilled 
gaps in previous drilling in the northern, down-dip part of the deposit as well as in the central area between the Ruby 
Zone and South Reef area.  Three additional holes were collared but were abandoned due to drilling problems.  

In  the  summer  of  2019,  Trilogy  Metals  completed  another  drilling  program  comprising  eight  holes  that  tested  the 
continuity of the mineralization within the Bornite deposit and two holes that tested exploration targets located about 
1 km south and southeast of the deposit. 

Between 2012 and 2014, Trilogy Metals geologists re-logged and re-sampled legacy drill holes in the Ruby Zone and 
South Reef area which were previously drilled and only selectively sampled by Kennecott. These assays were used in the 
estimation of the current mineral resource, except where duplicates of Kennecott samples were collected.  In the case 
of duplicates, the original assay information was given priority in the mineral resource database. 

In  the  initial  years  of  drilling  at  Bornite,  Kennecott  relied  on  AX  diameter  core  (30.2  mm  diameter),  but,  as  drilling 
migrated towards deeper targets, a  change to BX diameter core (41.3 mm diameter)  was implemented  to help limit 
deviation. From 1966 to 1967, drilling activity at Bornite moved underground and EX diameter core (21.5 mm diameter) 
was implemented to define the Ruby Zone Upper Reef “No.1 Ore Body”. In 1968, drilling activity moved back to the 
surface and from 1968 to 1972, BX diameter core was most commonly drilled. In later years, core size increased to NX 
(54.0 mm diameter) and finally, in 2011, core size increased to NQ (47.6 mm diameter) and HQ (63.5 mm diameter). 
Over the years, progressively larger diameter drill rods have been used in an effort to minimize drill hole deviations. 

There is limited information with respect to the specific drill core handling procedures used by BCMC/Kennecott. All drill 
data collected during 1957 to 1997 were logged on paper drill logs with copies were stored in the Kennecott office in Salt 
Lake City, Utah. Electronic, scanned copies of the paper logs are held by Trilogy and stored in the Fairbanks field office. 
Drill core was sawed or split in half with a splitter, half was submitted to various assay labratories and the remainder was 
stored in the Kennecott/BCMC core storage facility at the Bornite deposit. In 1995, Kennecott converted the drill assay 
data, geologic core logs and the down-hole collar survey data into an electronic format. In 2009, NOVAGOLD geologists 
verified the geologic data from the original paper logs against the Kennecott electronic format and then merged the data 
into a MicrosoftTM SQL database. Sampling of drill core by Kennecott/BCMC focused primarily on the moderate-to-high 
grade mineralized zones. Intervals of visible sulphide mineralization containing roughly >0.5% to 1% Cu were selected 
for analysis by Union Assay Office Inc. of Salt Lake City, Utah. This approach left numerous intervals containing weak to 
moderate copper mineralization, un-sampled in the historical drill core. During the 2012 exploration program, we began 
sampling a  portion of this remaining drill core in select holes in the South Reef area.  Trilogy  extended this sampling 
program to the Ruby Zone in 2013 and 2014. 

Throughout our tenure at Bornite, the following core handling procedures have been implemented (including programs 
conducted by NOVAGOLD and NovaCopper). Core is slung by helicopter or transported by truck or all-terrain vehicle 
from the drill rig to the core-logging facility. Upon delivery, geologists and geotechnicians open and inspect the core 

73 

boxes for any irregularities. They first mark the location of each drilling block on the core box, and then convert footages 
on the blocks into metric equivalents. Geo-technicians or geologists measure the intervals (or from/to) for each box of 
core and include this information, together with the drill hole ID and box number, on a metal tag stapled to the end of 
each box. Geo-technicians then measure the core to calculate percent recovery and rock quality designation (“RQD”). 
RQD is the sum of the total length of all pieces of core in a run over 12 cm. The total length of core in each run is measured 
and compared to the corresponding run length to determine percent recovery. Core is then logged with lithology and 
visual alteration features captured on observed interval breaks. Mineralization data, including sulphide species (recorded 
as percent), sulphide type (recorded as a relative amount) and gangue and vein mineralogy are collected for each sample 
interval with an average interval of approximately 2 m. Structural data is collected as point data. Geologists then mark 
sample  intervals  to  indicate  each  lithology  or  other  geologically  appropriate  intervals.  Sample  intervals  of  core  are 
typically between 1 m and 3 m in length but are not to exceed 3 m long. Occasionally, if warranted by the need for better 
resolution of geology or mineralization, smaller sample intervals have been used. Geologists staple sample tags on the 
core boxes at the start of each sample interval and mark the core itself with a wax pencil to designate sample intervals. 
This sampling approach is considered sound and appropriate for this style of mineralization and alteration. Drill core is 
digitally  photographed prior  to sampling.  Drill core is cut  in half using diamond core saws. Specific attention to core 
orientation is maintained during core sawing to ensure that representative samples are obtained. One-half of the core 
is retained in the core box for storage on site, or at our Fairbanks warehouse, and the other half is bagged and labeled 
for analysis. Samples are selected for specific gravity measurements. 

In 2013 and 2014, 33 historical drill holes and 37 historical drill holes, respectively, in the Ruby Zone were re-logged, re-
sampled and re-assayed as these holes had previously only been selectively sampled by Kennecott. Entire holes were re-
logged using Trilogy protocols discussed above. Samples were submitted either as half-core, where previously sampled, 
or  whole  core  where  un-sampled  (to  ensure  that  a  sufficient  volume  of  material  was  provided  for  analysis).  Sample 
intervals  were  matched  to  historical  intervals  whenever  possible  or  selected  to  reflect  Trilogy  sampling  procedures 
described above. The objectives of the re-assay/re-logging program were threefold: 1) to implement a QAQC program 
on intervals previously sampled by Kennecott in order to confirm the validity of its results; 2) to identify additional lower 
grade (0.2%-0.5% Cu), which was not previously sampled; and 3) to provide additional multi-element ICP data to assist 
in the geologic interpretation of the deposit. 

Preliminary  geotechnical  data  was  collected  from  drill  core  such  as  RQD  and  limited  hydrogeology  data  has  been 
obtained  which  is  sufficient  to  support  early-stage  resource  estimation.  The  Wood  QP  is  not  aware  of  any  drilling, 
sampling or recovery factors that could materially impact the accuracy and reliability of the copper results supporting 
the mineral resource estimate. 

Sampling, Analysis and Data Verification 

There is limited documentation available describing the sample preparation, security, and analysis of drill core samples 
collected between 1957 and 1997. These assumptions are based on the old assay certificates and some sample ledgers 
with mixed in QAQC check assays.  Gold and silver were likely analyzed by fire assay off site. Between 2012 and 2014, 
Trilogy Metals completed a re-assay and re-sampling program of the historical drill holes.  As a result, 67% of the historical 
hole assay values are now supported by a current and documented QAQC program 

The drill core sampling procedures are described above. After the drill core was sawed in half, one half was retained for 
future reference and the other half was sent to ALS Minerals (formerly ALS Chemex) in Vancouver, British Columbia for 
analyses. Core samples were shipped from the Bornite camp when backhaul capacity was available on the chartered 
aircraft; this was generally five to six days a week. Rice bags, containing two to four individual poly-bagged core samples, 
were marked and labeled with the ALS Minerals address, project name (Bornite), drill hole number, bag number, and the 
enclosed sample numbers. Rice bags were secured  with a pre-numbered plastic security tie, assembled into loads for 
transport by chartered flights on a commercial airline to Fairbanks, Alaska, and delivered directly to the ALS Minerals 
preparation facility by a contracted expeditor. Control samples were also inserted into these shipments at the rate of 
one standard, one blank and one duplicate per 17 core samples. Samples were logged into a tracking system on arrival 

74 

at ALS Minerals and weighed. Samples were then crushed, dried, and a 250 g split was pulverized to greater than 85% 
passing 75 μm. 

Security measures taken during historical Kennecott and BCMC programs are not known to Trilogy Metals; however, 
Trilogy Metals is not aware of any reason to suspect that any of these samples have been tampered with.  The 2011 to 
2019 samples were either in the custody of NOVAGOLD or Trilogy Metals personnel, or the assay laboratories at all times 
and the chain of custody of the samples is well documented. 

Copper and cobalt data were derived using a 48-element suite assayed by inductively coupled plasma-mass spectrometry 
(ICP-MS)  and  atomic  emission  spectroscopy  (ICP-AES)  methodologies,  following  a  four-acid  digestion.  The  lower 
detection limits for copper and cobalt are 0.2ppm and 0.1 ppm, respectively. The upper limits were 10,000ppm. Over 
limit (>1.0%) copper and cobalt analyses were completed by atomic absorption (AA), following a four-acid digestion. In 
2011 and 2012, gold assays were determined using fire analysis followed by an atomic absorption spectroscopy (AAS) 
finish. Gold was not analyzed in 2013 or 2014. The lower detection limit was 0.005 ppm Au; the upper limit was 10 ppm 
Au. 

ALS Minerals has attained International Organization for Standardization (ISO) 9001:2000 registration. In addition, the 
ALS Minerals laboratory in Vancouver is accredited to ISO 17025 by Standards Council of Canada for a number of specific 
test procedures including fire assay of gold by AA, ICP and gravimetric finish, multi-element ICP and AA assays for silver, 
copper, lead and zinc. Trilogy has no relationship with any of the primary or check assay labs used on the Bornite Project. 

In 2012, 2013, 2014, and 2017 through to 2019, Trilogy Metals staff performed continuous validation of the drill data 
during  the  logging  process  and  after  the  field  program  was  complete.  Trilogy  Metals  also  retained  independent 
consultant GeoSpark Consulting Inc. (“GeoSpark”) to import digital drill data to the master database and conduct QAQC 
checks upon import; conduct a  QAQC review of paired historical assays and Trilogy Metals 2012, 2013 and 2014 re-
assays; monitor an independent check assay program for the 2012, 2013 and 2014 campaigns; and generate a QAQC 
report for each of the drilling campaigns conducted in 2012, 2013, 2014, 2017, 2018 and 2019, including a 2017 review 
of the cobalt data. QAQC monitoring by GeoSpark included assessment laboratory precision and accuracy using assay 
results  from  certified  reference  standards,  blanks  and  duplicates  inserted  into  the  sample  stream  by  Trilogy  Metals 
personnel. 

Wood’s geology and resource QP visited the Bornite property from August 29 to September 9, 2022.  During the visit, he 
reviewed drill core, measured drill collars with a handheld GPS unit, visited the historical trench area and viewed the 
deposit area by helicopter. Wood’s geology and resource QP also measured five surface drill collars with a handheld GPS 
unit. Out of five drill collars, one drill collar was off more than 40 m when compared to the collar database. After further 
investigation,  Ambler  Metals  identified  seven  drill  collars  in  the  database  with  planned  coordinates,  rather  than  the 
surveyed coordinates. The QP has reviewed the metallurgical testwork reports, the analytical procedures, qualification 
of the laboratory, and presentation of the test results and considers all to have followed industry accepted practice. 

Inspection of the historical drill hole data has revealed some issues with collar, down hole survey and assay results.  There 
are 183 historical holes representing 46% of the total drilled metres in the Bornite database 177 of which are in the Ruby 
Zone  and  six  of  which  are  in  the  South  Reef  area.    There  are  no  significant  concerns  with  the  current  collar  survey 
records.Issues identified are manageable by the significant number of drilling and sampling that has been undertaken, 
and restriction of the resource classification to the Inferred category. 

Wood’s  geology  and  resource  QP’s  review  of  the  database  transcription  error  checks  is  considered  adequate  and 
provides  sufficient  support  for  the  database  to  be  judged  as  acceptably  error  free.  In  the  opinion  of  the  QP  the 
metallurgical data is adequate for the purposes used in the NI 43-101 Bornite Report and the S-K 1300 Bornite Report. 

Mineral Processing and Metallurgical Testing 

In 1961, Kennecott collected 32 coarse reject samples from five drill holes intersecting the Bornite deposit (RC-34, RC-
54, RC-60, RC-61, and RC-65) to support preliminary metallurgical testwork conducted at KRC.  Samples targeted high-

75 

grade (>10%) copper  mineralization from the Ruby Zone  Upper Reef  (“No. 1 Ore Body”) (BCMC, 1961). Locked-cycle 
laboratory testwork suggested that 97.64% of the copper was recoverable in a concentrate assaying 43.90% Cu.  Fine-
grinding to 5% passing +200-mesh was required to obtain the liberation of copper minerals from pyrite necessary for 
such a high recovery.  Mineralogical testwork on the composite sample showed high-grade mineralization of the Ruby 
Zone Upper Reef is dominated by bornite with subordinate chalcocite and chalcopyrite. 

A total of four metallurgical testwork programs have been conducted on materials from the Bornite Property under the 
supervision of Trilogy Metals. 

In 2012, Trilogy Metals contracted ALS Metallurgy to conduct preliminary sample characterization and flotation testwork 
on mineralized samples collected from the South Reef area.  To the extent known, the samples are representative of the 
styles and types of mineralization present in the South Reef area. The program at ALS Metallurgy was based on traditional 
grinding and flotation testwork aimed at producing saleable copper concentrates. The testwork continued into 2013. 

In 2017, Trilogy Metals contracted SGS to conduct detailed metallurgical testwork on a series of samples that represent 
the  lower  grade  mineralization  within  the  constraining  pit  shell.  This  work  followed  the  preliminary  flowsheet  and 
process options outlined in the 2012/2013 testwork.  This testwork continued into 2018. 

Additional metallurgical testing was conducted by ALS Metallurgy in 2018/2019 and again in 2020/2021 which followed 
on from the process development of the earlier testwork.  

Metallurgical  testwork  to  date  indicates  that  the  Bornite  mineralization  can  be  treated  using  standard  grinding  and 
flotation methods to produce clean copper concentrates with good results being obtained.  Copper recoveries range  

Mineral Resource Estimates  

The mineral resources were  prepared in accordance with CIM Estimation of Mineral Resources and Mineral Reserves 
Best  Practice  Guidelines  (November  2019)  and  reported  in  accordance  with  CIM  Definition  Standards  for  Mineral 
Resources and Mineral Reserves (CIM Definitions Standards, 2014) and the standards and definitions of S-K 1300..   The 
QP  considers  the  sample  preparation,  security  and  analytical  procedures  adequate  to  support  an  Inferred  mineral 
resource. 

The Bornite database comprises a total of 273 diamond drill (core) holes totalling 106,406 m; 203 holes target the Ruby 
Zone  to  the  west  and  58  holes  target  the  South  Reef  area  to  the  east.  The  remaining  12  holes  in  the  database  are 
exploratory  in  nature  and  test  for  satellite  mineralization  proximal  to  the  Bornite  deposit  or  represent  holes  that 
encountered  problems  and  were  therefore  abandoned.  A  total  of  242  drill  holes  are  used  in  the  mineral  resource 
estimate contains a total of 39,740 samples that were analyzed for copper content and 34,177 that were analyzed for 
cobalt content. Most holes drilled by Trilogy, plus a few select historical holes drilled by Kennecott, contain additional 
analyses for elements such as zinc, lead, gold, silver, and cobalt. At this time, only copper has reasonable prospectus for 
eventual economic extraction. 

During the 2012, 2013 and 2014 field seasons, Trilogy collected samples from drill hole intervals that were not previously 
sampled. It is assumed that Kennecott did not sample these intervals because, visually, they did not exhibit the presence 
of high-grade copper mineralization (amenable to underground mining). In previous mineral resource estimates, these 
un-sampled intervals were assigned a default grade of 0% Cu. At this current stage, the majority of the core drilled by 
Kennecott  has  been  sampled  and  analyzed  for  copper  content  and  are  included  in  the  database.  The  sampling  and 
assaying for cobalt is less extensive. Where assay data are not available, these intervals are assigned a zero grade for 
cobalt (0% Co) when the host rocks are phyllite, or they are left blank when the host rocks are carbonates. Individual 
sample intervals range from 3 cm to 39.58 m long and average 2.09 m. 

Drill hole spacing at the Ruby Zone varies from approximately 10 m to 20 m for underground holes and 50 m to 100 m 
or  more  for  holes  drilled  from  surface.  All  holes  testing  the  South  Reef  area  are  collared  from  surface  and  typically 
intersect mineralization at approximately 100 m to 200 m spacing. 

76 

Specific gravity (“SG”) measurements were conducted on 7,476 samples in the database and range from a minimum of 
2.12 to a maximum of 5.20 and average 2.89. The distribution of SG data is considered sufficient to support resource 
estimation. 

The  geologic  model  interpreted  for  the  Bornite  deposit  consists  primarily  of  a  series  of  inter-bedded  carbonate  and 
phyllitic  rocks  that  dip  gently  to  the  north  and  overlay  a  quartz-phyllite  footwall.  The  geologic  model  comprises  18 
individual  phyllite  domains  and  16  separate  carbonate  domains  plus  a  series  of  separate  domains  representing  the 
hanging wall (Beaver Creek phyllite), the footwall (quartz-phyllite Anirak schist), and the overlying overburden. Some of 
the  phyllite  and  carbonate  units  are  continuous  across  the  entire  deposit  area  and  others  pinch  out  and  are  more 
localized. 

The  parts  of  the  deposit  with  the  highest  grades  occur  within  areas  where  semi-massive  and  massive  sulphides  are 
present. The density of drilling is insufficient  in most  areas to allow for the interpretation of these massive sulphide 
domains, and a probability shell approach is used to identify areas where higher grade mineralization is likely to occur. 

Two probability shells were generated: one at a threshold of 2% Cu and another at a threshold of 0.2% Cu. The 2% Cu 
shell  generally  correlates  with  the  presence  of  massive  and  semi-massive  zones  of  bornite  and  chalcopyrite 
mineralization,  and  the  0.2%  Cu  shell  correlates  with  the  visual  presence  of  chalcopyrite  mineralization.  Cobalt 
mineralization is strongly associated with both sets of copper mineralization. The higher grade shell occurs mainly in the 
South  Reef  area  and  is  based  primarily  on  visual  observations  of  the  distribution  of  sample  data  suggesting  that  a 
relatively continuous zone of higher grade copper mineralization occurs above a threshold grade of 2% Cu. Approximately 
90% of the sample data in the South Reef area is below 2% Cu and 10% of the data is greater than 2% Cu. A relatively 
small (>2%) copper probability shell is also generated in the Upper Reef area of the Ruby Zone. 

Approximately one half of the samples in the carbonate domains have copper grades above the lower grade threshold 
of  0.2%  copper.  This  limit  roughly  segregates  areas  of  mineralized  versus  unmineralized  rocks  and  is  still  below  the 
anticipated  cut-off  grade  of  the  mineral  resource,  ensuring  that sufficient  internal  dilution  is  retained  in  the  mineral 
resource model. There are also areas where the phyllite domains contain appreciable copper grades (above the 0.2% Cu 
threshold), but these tend to be rare and localized occurrences. 

Indicator  values  are  assigned  to  2  m  composites  at  the  grade  thresholds,  and  indicator  variograms  are  produced. 
Probability values are estimated in model blocks using ordinary kriging; the vertical range and locations are controlled 
dynamically using elevations relative to the trend planes described previously. A series of shells are generated at varying 
probability thresholds and are then compared to the distribution of the underlying sample data. The higher grade shell 
represents areas where there is greater than a 30% probability that the grade will be more than 2% Cu. The lower grade 
shell envelopes areas where there is a greater than 50% probability that the grade will exceed 0.2% Cu. 

At this stage of project evaluation, copper is the only economic contributor at Bornite. There is potential for reasonable 
prospects  of  eventual  economic  extraction  for  cobalt  with  additional  drill  information  and  metallurgical  testwork  to 
establish the appropriate process options available to produce marketable pyrite-cobalt concentrate. Currently there is 
insufficient  information  to  identify  reasonable  process  method  for  economic  recovery  of  cobalt  or  a  market  for  the 
pyrite-cobalt concentrate. The Bornite deposit comprises several zones of relatively continuous moderate- to high-grade 
copper mineralization that extends from surface to depths of more than 800 m below surface. The deposit is amenable 
to either open pit or underground mining methods. Underground mining assumes a combination of longhole stoping 
and cut-and-fill methods with an average assumed mining cost  $73.62/t  mined. Using these parameters an open pit 
marginal cut-off  grade of 0.5% Cu  and an underground break-even  cut-off grade of 1.79% Cu were determined.  The 
underground mining shape is based on a 1.79% Cu grade shell and then a filter was applied to remove isolated blocks 
that are outside of the underground mining shape that would not meet reasonable prospects for eventual economic 
extraction. A 20 m pillar was imposed between mining the pit shell and underground mining shapes. 

The Wood QP considers industry consensus on a long-term price forecast on mineral reserves and cash flows of $3.50/lb 
Cu is reasonable. It is in accordance with industry-accepted practice to use higher metal prices for the mineral resource 

77 

estimates  than  the  pricing  used  for  mineral  reserves.    The  copper  price  forecast  of  $3.50/lb  was  increased  by 
approximately 15% to provide the mineral resource estimate copper price assumption of $4.05/lb. 

Mineral Resources are classified in accordance with S-K 1300 and the CIM Definition Standards for Mineral Resources 
and Mineral Reserves (May 2014). 

The  Wood  QP  reviewed  and  performed  validation  checks  on  the  mineral  resource  model  and  based  on  the  results 
prepared a revised mineral resource statement that is summarized in Table 1.  The mineral resource estimates are based 
on  a  combination  of  open  pit  and  underground  mining  methods  and  a  copper  price  of  $4.05/lb.    Mineral  resources 
amenable to open pit methods are constrained within a pit shell above a marginal cut-off grade of 0.5% Cu and those 
amenable by underground methods are constrained within a grade shell defined by a breakeven cut-off grade of 1.79% 
Cu.  A portion of the in-pit mineral resource is well above the 1.79% Cu cut-off and would be amenable to underground 
mining methods providing flexibility on how to develop the deposit (Table 2). 

Table 1 – Mineral Resources for the Bornite Deposit as of November 30, 2022  

Inferred 

Class 

Type/Area 

In-Pit 

Outside-Pit 
South Reef 

Outside-Pit 
Ruby Zone 

Total Inferred – 100% 

Total Inferred – 50% 
Attributable Interest 
Note: 

Cut-off 
(Cu %) 

0.50 

1.79 

1.79 

Tonnes 
(Mt) 

170.4 

22.0 

10.4 

202.7 

101.3 

Average Grade 
Cu (%) 

Contained Metal 
Cu (Mlb) 

1.15 

3.48 

2.28 

1.46 

4,303 

1,690 

521 

6,514 

3,257 

1.  The mineral resources are current as of November 30, 2022 and were prepared by a Wood QP.   
2.  Mineral resources are prepared in accordance with the definitions in S-K 1300 and CIM Definitions Standards (2014). No 

mineral reserves have been estimated on the Bornite Property. 

3.  Mineral resources are constrained by:  an open pit shell at a cut-off grade of 0.5% Cu, with an average pit slope of 43 

degrees; and underground mining shapes with a cut-off grade of 1.79% Cu.  The cut-off grades include the considerations 
of a $4.05/lb Cu price, process recovery of 87.2%, open pit mining costs of $3.21/t mined, underground mining cost of 
$73.62/t mined, process cost of $19.14/t processed, G&A cost of $4.14/t processed, treatment, refining, sales cost of 
$0.73/lb Cu in concentrate, road use cost of $8.04/t processed, 2% NSR royalty.   

4.  Trilogy Metals’ attributable interest is 50% of the tonnage and contained metal stated in the table. 
5. 

Figures may not sum due to rounding. 

6.  The mineral resources are reported in place (point of reference). 

78 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 2 – Portions of South Reef Mineral Resource Amenable to Underground Mining 

Class 

Inferred 

Inferred 

Type/Area 
In-Pit South Reef1 
Outside-Pit South Reef2 
Total South Reef 

Cut-off 
(Cu %) 
1.79 
1.79 

Tonnes 
(Mt) 
11.0 
22.0 
33.0 

Average Grade 
Cu (%) 
3.56 
3.48 
3.51 

Contained Metal 
Cu (Mlb) 
864 
1,690 
2,554 

Note:  (1)  Subset of the mineral resource and is not additive to the in-pit mineral resource reported in Table 1 

(2)  Restatement of the mineral resources outside of the pit as reported in Table 1 and is not additive to Table 1 

Some of the in-pit mineral resources are of sufficiently high grade to allow mining by underground mining methods which 
allows flexibility on how they could eventually be extracted. 

Additional factors that could affect the mineral resource estimate include: 

•  Unrecognized complexity and other changes to the interpretation of the geological model and grade shell 

• 

Changes to the mineral resource estimate methodology 

•  Adjustments to address the perceived high-grade bias in the higher-grade copper 

•  Unrecognized metallurgical variability  

•  Additional  work  may  allow  the  inclusion  of  cobalt  in  future  updates  to  the  mineral  resource  statement  and 

expand the mineral resource. 

•  Approval for developing road access to site. 

Exploration, Development, and Production 

Based on the mineral resource estimates and existing metallurgical testwork presented in this NI 43-101 Bornite Report 
and S-K 1300 Bornite Report, the QPs recommend Trilogy Metals continue to improve their understanding of the Bornite 
property’s structural geology and their confidence in the database with additional re sampling, drilling and database 
reviews,  scoping  study  as  well  as  conduct  additional  metallurgical  testwork,  hydrogeological  and  geotechnical 
assessments, and environmental studies totalling between $16.8 and $19.9 million. 

Exploration Potential 

Outcropping  exposures  of  the  mineralization-hosting  carbonate  stratigraphy  along  with  large  areas  of  dolomite 
alteration occur over approximately 18 km of strike along the northern flank of the Cosmos Hills.  Historical exploration 
drilling focused solely on outcropping mineralization and subsurface extensions at the Bornite, Aurora Mountain, and 
Pardner Hill areas.  Much of the carbonate belt has still yet to be evaluated.  In addition, airborne geophysics completed 
in 2006 show the Bornite carbonate sequence and the bounding stratigraphy dip to the north under the Ambler Lowlands 
toward the Ambler Schist Belt.  This opens a large area to explore for deposits beneath the till and recent sediments that 
occupy the lowlands. 

Exploration by Kennecott and Trilogy Metals has used a variety of methodologies. In 1996, Kennecott completed an initial 
gravity survey of the Ambler Lowlands showing significant gravimetric anomalies that may indicate structural dislocations 
and potential alteration and mineralization.  In 2011, Trilogy Metals investigated both deep IP and NSAMT geophysical 
techniques.  Results from the 2011 program led to a 2012 district-wide, 200 m dipole-dipole, deep-penetrating IP survey.  

79 

 
 
 
 
 
 
 
 
 
Along with extensive physical property data captured for all lithologies, airborne EM and magnetic data, the IP data was 
used to develop a  comprehensive geophysical model of the district  to support  future exploration targeting. In 2017, 
Trilogy  Metals  conducted  a  more  detailed  gravity  survey  that  delineated  significant  north-northeast  to  northeast 
oriented structures which appear in part to control local basin morphology and mineralization. 

Geochemical methods include conventional and DPG and lithogeochemical vectoring.  Test lines using DPG methods with 
various  selective  partial  leaches  of  metals  proved  effective  in  recognizing  margins  of  South  Reef  mineralization  at 
significant depths under cover.  A recent analysis of the extensive ICP trace element data set at Bornite demonstrates 
some  significant  alteration  vectors  including  iron  content  of  various  hydrothermal  dolomites.  Simple  XRF  analysis  of 
dolomites in the field might prove effective in vectoring toward Fe-poor mineralized dolomite sections. 

A better understanding of the basin development and its structural framework is critical to the exploration of Bornite-
style systems. Dating of mineralization in the Ambler Mining District suggests that the Ambler schist belt that hosts the 
Arctic deposit and the Bornite carbonate-hosted mineralization are close to contemporaneous.  However, some textural 
and metamorphic observations suggest a possible Jura-Cretaceous or younger age for Bornite and as such, mineralization 
at  Bornite  is  suspected  to  slightly  post-date  host  stratigraphy.  This  early  and  extensive  syngenetic/early  epigenetic 
signature, along with the overall fluid chemistry of the system investigated by early workers, such as Hitzman (1983 and 
1986), point to large saline basin-generated fluid transport as the mechanism controlling the metallogeny of the Ambler 
Mining District.  Importantly, similar metallogenies related to saline, basin-generated fluids and their associated deposits 
form some of the largest copper districts in the world. 

The Bornite Project is not currently in production; for contemplated exploration or development activities see above. 

Internal Controls Over Mineral Resource and Reserve Estimates 

Trilogy has internal controls for reviewing and documenting the information supporting the mineral resource and mineral 
reserve estimates, describing the methods used, and ensuring the validity of the estimates. 

Information that is used to compile mineral resources and reserves is prepared and certified by appropriately qualified 
persons  at  the  project  sits  and  is  subject  to  our  internal  review  process  which  includes  review  by  appropriate 
management and a Qualified Person employed by Trilogy. 

The  corporate  Qualified  Person  presents  the  mineral  resource  and  reserve  information  to  the  Board’s  Technical 
Committee for their review on a periodic basis. 

Mineral Reserve and Resource Estimate Comparison Between November 30, 2022 and 2021 

For  the  year  ended  November  20,  2021,  Trilogy  was  not  subject  to  S-K  1300,  and  reported  its  mineral  reserve  and 
resources in accordance with NI 43-101.  7.  For ease of comparison, the estimates for each project are shown on a 100% 
basis.  Trilogy’s attributable interest is 50% of the tonnage and contained metal stated in the tables. 

Mineral Reserves Comparison for Arctic 

Category 

Probable 

Tonnage 
(Mt) 
2022 

46.7 

Tonnage 
(Mt) 
2021 

43.4 

Percentage 
Change 

7.4% 

80 

 
 
 
  
 
 
 
 
 
Mineral Resources Comparison for Arctic 

Resource 

Tonnage 

Contained Metal Content 

Category 

Indicated (2021) (note 1) 

Indicated (2022) 

% Change 

Inferred (2021) 

Inferred (2022) 

% Change 

(Mt) 

36.0 

- 

100% 

3.5 

4.5 

Cu 

(Mlb) 

2,441 

- 

Pb 

(Mlb) 

581 

- 

Zn 

(Mlb) 

3,356 

- 

Au 

(koz) 

728 

- 

Ag 

(Moz) 

55 

- 

100% 

100% 

100% 

100% 

100% 

131 

189 

47 

69 

210 

288 

40 

62 

3 

5 

28.5% 

44.2% 

46.8% 

37.1% 

55.0% 

66.6% 

note 1: Under S-K 1300, mineral resources are shown exclusive of reserves.  Due to the reporting change, no indicated resources are 
indicated for 2022.  In 2021, mineral resources are reported under NI 43-101 inclusive of reserves. 

Mineral Resources Comparison for Bornite 

Category 

Tonnes 
(Mt) 
2022 

Tonnes 
(Mt) 
2021 

Percentage 
Change 

Contained 
Metal Cu 
(Mlb) 

Contained 
Metal Cu 
(Mlb) 

Percentage 
Change 

Inferred In-Pit 

Inferred Outside Pit South Reef 

Inferred Outside Pit Ruby Zone 

Total Inferred 

170.4 

22.0 

10.4 

202.7 

93.9 

35.3 

15.0 

144.2 

8.1% 

(37.6%) 

(30.6%) 

40.6% 

2022 

4,303 

1,690 

521 

6,514 

2021 

2,034 

2,639 

653 

5,326 

111.5% 

(35.9%) 

(20.2%) 

22.3% 

In  2022,  in-pit  mineral  resources  increased  by  increasing  the  size  of  the  pit  to  maximize  the  copper  resource.    This 
resulted in reduction of the mineral resources from outside of the pit. 

Item 3.     LEGAL PROCEEDINGS 

From time to time, we are a party to routine litigation and proceedings that are considered part of the ordinary course 
of  business.  We  are  not  aware  of  any  material  current,  pending,  or  threatened  litigation.  There  are  no  material 
proceedings pursuant to which any of our directors, officers or affiliates or any owner of record or beneficial owner of 
more than 5% of our securities or any associate of any such director, officer or security holder is a party adverse to us or 
has a material interest adverse to us. 

81 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Item 4.     MINE SAFETY DISCLOSURES 

Operations are subject to regulation by the Federal Mine Safety and Health Administration (“MSHA”) under the Federal 
Mine Safety and Health Act of 1977 (the “Mine Act”).  At our current stage of exploration, we are not yet subject to 
MSHA. 

Companies required to file periodic reports under the Exchange Act, that operate mines regulated under the Mine Act 
are  required  to  make  certain  disclosures  pursuant  to  Section  1503(a)  of  Dodd-Frank.    We  have  nothing  to  disclose 
pursuant to Section 1503(a) of Dodd-Frank for the fiscal year ended November 30, 2022. 

PART II 
Item 5.    MARKET FOR REGISTRANT’S COMMON EQUITY, RELATED STOCKHOLDER 

MATTERS AND ISSUER PURCHASES OF EQUITY SECURITIES 

The Company’s common stock is traded on the TSX and the NYSE American under the symbol “TMQ”. As of February 14, 
2023, there were 1,456 registered holders of our Common Shares. 

Dividend Policy 

We have not declared or paid any dividends on our Common Shares. Our current business plan requires that for the 
foreseeable future, any future earnings be reinvested to finance the growth and development of our business. We will 
not declare or pay any dividends until such time as our cash flow exceeds our capital requirements and will depend upon, 
among  other  things,  conditions  then  existing  including  earnings,  financial  condition,  restrictions  in  financing 
arrangements, business opportunities and conditions and other factors, or our Board determines that our shareholders 
could make better use of the cash. 

Unregistered Sales of Equity Securities 

None. 

Repurchase of Securities 

During fiscal year 2022, neither Trilogy nor any affiliate of Trilogy repurchased Trilogy Common Shares. 

Exchange Controls 

There are no governmental laws, decrees or regulations in Canada that restrict the export or import of capital, including 
foreign exchange controls, or that affect the remittance of dividends, interest or other payments to non-resident holders 
of the securities of Trilogy, other than Canadian withholding tax. 

Certain Canadian Federal Income Tax Considerations for U.S. Holders 

The following is a  general summary of the principal Canadian federal income tax  considerations generally  applicable 
under Income Tax Act (Canada) (the “Tax Act”) to a holder of Common Shares, each of whom, at all relevant times, for 
the purposes of the Tax Act, holds such Common Shares as capital property, deals at arm’s length with the Company, is 
not affiliated with the Company and, for purposes of the Tax Act, is not, is not deemed to be, a resident of Canada and 
has not and will not use or hold or be deemed to use or hold the Common Shares in the course of carrying on business 
in  Canada  (a  “Non-Resident  Holder”).  Special  rules,  which  are  not  discussed  below,  may  apply  to  a  non-resident  of 
Canada that is an insurer which carries on business in Canada and elsewhere.  Such Non-Resident Holders should consilt 
their own tax advisors. 

The Common Shares will generally be considered capital property to a Non-Resident Holder unless either (i) the Non-
Resident Holder holds the Common Shares in the course of carrying on a business of buying and selling securities or 

82 

(ii) the  Non-Resident  Holder  has  acquired  the  Common  Shares  in  a  transaction  or  transactions  considered  to  be  an 
adventure or concern in the nature of trade. 

The term “U.S. Holder,” for the purposes of this section, means a Non-Resident Holder who, for purposes of the Canada-
United States Tax Convention (1980) as amended, (the “Convention”), is at all relevant  times a resident of the United 
States and is a “qualifying person” within the meaning of the Convention. In some circumstances, fiscally transparent 
entities (including limited liability companies) will be entitled to benefits under the Convention.  Non-Resident Holders 
are urged to consult with their own tax advisors to determine their entitlement to benefits under the Convention based 
on their particular circumstances. 

This  summary  is  based  on  the  current  provisions  of  the  Tax  Act,  the  regulations thereunder  (the  “Regulations”),  the 
current  provisions  of  the  Convention,  counsel’s  understanding  of  the  current  published  administrative  policies  and 
assessing practices of the Canada Revenue Agency (the “CRA”) publicly available prior to the date hereof. This summary 
also takes into account all specific proposals to amend the Tax Act and Regulations publicly announced by or on behalf 
of  the  Minister  of  Finance  (Canada)  prior  to  the  date  hereof  (collectively,  the  “Proposed  Tax  Amendments”).  No 
assurances can be given that the Proposed Tax Amendments will be enacted or will be enacted as proposed. Other than 
the  Proposed  Tax  Amendments,  this  summary  does  not  take  into  account  or  anticipate  any  changes  in  law  or  the 
administration  policies  or  assessing  practice  of  CRA,  whether  by  judicial,  legislative,  governmental  or  administrative 
decision or action, nor does it take into account provincial, territorial or foreign income tax legislation or considerations, 
which may differ significantly from those discussed herein. 

This summary is of a general nature only and is not intended to be, nor should it be construed to be, legal or tax advice 
to any particular Non-Resident Holder and no representations with respect to the income tax consequences to any 
particular  Non-Resident  Holder  are  made.  This  summary  is  not  exhaustive  of  all  Canadian  federal  income  tax 
considerations.  Accordingly,  Non-Resident Holders should consult  their own tax advisors with respect to their own 
particular circumstances. The discussion below is qualified accordingly. 

Currency Conversion 

Subject  to  certain  exceptions  that  are  not  discussed herein,  for  purposes  of  the  Tax  Act,  all  amounts  relating  to  the 
acquisition,  holding  or  disposition  of  Common  Shares,  including  dividends,  adjusted  cost  base  and  proceeds  of 
dispositions must be determined in Canadian dollars using the daily exchange rate of the Bank of Canada on the particular 
date the particular amount arose or such other rate of exchange as acceptable to the CRA. 

Disposition of Common Shares 

A Non-Resident Holder will not be subject to tax under the Tax Act in respect of any capital gain realized by such Non-
Resident Holder on a disposition of the Common Shares, nor will capital losses arising from the disposition be recognized 
under the Tax Act, unless the Common Shares constitute “taxable Canadian property” (as defined in the Tax Act) of the 
Non-Resident Holder at the time of disposition and the Non-Resident Holder is not entitled to relief under an applicable 
income tax treaty or convention. As long as the shares are then listed on a “designated stock exchange” (as defined in 
the Tax Act) (which currently includes the TSX and the NYSE American) at the time of disposition, the Common Shares 
generally will not constitute taxable Canadian property of a Non-Resident Holder, unless at any time during the 60-month 
period immediately preceding the disposition the following two conditions are met concurrently: (i) the Non-Resident 
Holder,  persons  with  whom  the  Non-Resident  Holder  did  not  deal  at  arm’s  length,  partnerships  in  which  the  Non-
Resident Holder or persons with whom the Non-Resident Holder did not deal at arm’s length holds a membership interest 
directly  or  indirectly  through  one  or  more  partnerships,  or  the  Non-Resident  Holder  together  with  all  such  persons, 
owned or was considered to own 25% or more of the issued shares of any class or series of shares of the capital stock of 
the Company; and (ii) more than 50% of the fair market value of the Common Shares was derived directly or indirectly 
from  one  or  any  combination  of  real  or  immovable  property  situated  in  Canada,  “Canadian  resource  properties”  (as 
defined in the Tax Act), “timber resource properties” (as defined in the Tax Act) or a options in respect of, or interests 
in, or civil law rights in, such properties, whether or not it exists. 

83 

If  the  Common  Shares  are  taxable  Canadian  property  to  a  Non-Resident  Holder,  any  capital  gain  realized  on  the 
disposition or deemed disposition of such shares, may not be subject to Canadian federal income tax pursuant to the 
terms of an applicable income tax treaty or convention between Canada and the country of residence of a Non-Resident 
Holder, including the Convention. 

A Non-Resident Holder whose shares are taxable Canadian property should consult their own advisors. 

Dividends on Common Shares 

Under the Tax Act, dividends on Common Shares paid or credited to a Non-Resident Holder will be subject to Canadian 
withholding tax at the rate of 25% of the gross amount of the dividends. This withholding tax may be reduced pursuant 
to the terms of an applicable income tax treaty or convention between Canada and the country of residence of a Non-
Resident Holder. Under the Convention, a U.S. Holder will generally be subject to Canadian withholding tax at a rate of 
15% of the gross amount of such dividends (or 5% in the case of a U.S. Holder that is a company beneficially owning at 
least 10% of the Company’s voting shares). In addition, under the Convention, dividends may be exempt from Canadian 
non-resident withholding tax if paid to certain U.S. Holders that are qualifying religious, scientific, literary, educational 
or  charitable  tax-exempt  organizations  and  qualifying  trusts,  companies,  organizations  or  arrangements  operated 
exclusively to administer or provide pension, retirement or employee benefits that are exempt from tax in the United 
States and that have complied with specific administrative procedures. 

Certain U.S. Federal Income Tax Considerations 

The following is a general summary of certain anticipated U.S. federal income tax considerations applicable to a U.S. 
Holder (as defined below) arising from and relating to the acquisition, ownership and disposition of Common Shares. 

This summary is for general information purposes only and does not purport to be a complete analysis or listing of all 
potential U.S. federal income tax considerations that may apply to a U.S. Holder as a result of acquisition of Common 
Shares. Furthermore, this summary does not take into account the individual facts and circumstances of any particular 
U.S. Holder that may affect the U.S. federal income tax considerations applicable to such U.S. Holder of Common Shares. 
Except  as  specified  below,  this  summary  does  not  discuss  applicable  tax  reporting  requirements.  Accordingly,  this 
summary is not intended to be, and should not be construed as, legal or U.S. federal income tax advice with respect to 
any U.S. Holder. U.S. Holders should consult their own tax advisors regarding the U.S. federal, U.S. state and local, and 
foreign tax consequences relating to the acquisition, ownership and disposition of Common Shares. 

No ruling from the U.S. Internal Revenue Service (the “IRS”) or legal opinion has been requested, or will be obtained, 
regarding the potential U.S. federal income tax considerations applicable to U.S. Holders as discussed in this summary. 
This summary is not binding on the IRS, and the IRS is not precluded from taking a position that is different from, and 
contrary to, the positions taken in this summary. In addition, because the authorities on which this summary is based 
are subject to various interpretations, the IRS and the U.S. courts could disagree with one or more of the positions taken 
in this summary. 

Scope of this Summary 

Authorities 

This summary is based on the U.S. Internal Revenue, as amended (“Code”), regulations promulgated by the Department 
of the Treasury (whether final, temporary or proposed) (“Treasury Regulations”), U.S. court decisions, published rulings 
and administrative positions of the IRS, and the Convention, that are applicable and, in each case, in effect as of the date 
of this document. Any of the authorities on which this summary is based could be changed in a material and adverse 
manner at any time, and any such change could be applied on a retroactive or prospective basis, which could affect the 
U.S. federal income tax considerations described in this summary. This summary does not discuss the potential effects, 
whether adverse or beneficial, of any proposed legislation that, if enacted, could be applied on a retroactive basis. 

84 

U.S. Holders 

For purposes of this section, a “U.S. Holder” is a beneficial owner of Common Shares that, for U.S. federal income tax 
purposes, is (a) an individual who is a citizen or resident of the United States for U.S. federal income tax purposes; (b) a 
corporation, or other entity classified as a corporation for U.S. federal income tax purposes, that is created or organized 
in or under the laws of the United States or any state in the United States, including the District of Columbia; (c) an estate 
if the income of such estate is subject to U.S. federal income tax regardless of the source of such income; or (d) a trust if 
(i) such trust has validly elected to be treated as a U.S. person for U.S. federal income tax purposes, or (ii) a U.S. court is 
able  to  exercise  primary  supervision  over  the  administration  of  such  trust  and  one  or  more  U.S.  persons  have  the 
authority to control all substantial decisions of such trust. 

Non-U.S. Holders 

For purposes of this summary, a “Non-U.S. Holder” is a beneficial owner of Common Shares that is neither a U.S. Holder 
nor  a  U.S.  partnership  (or  other  “pass-through”  entity).  This  summary  does  not  address  the  U.S.  federal  income  tax 
considerations applicable to Non-U.S. Holders relating to the acquisition, ownership and disposition of Common Shares. 
Accordingly, Non-U.S. Holders should consult their own tax advisors regarding the U.S. federal, U.S. state and local, and 
foreign  tax  consequences  (including  the  potential  application  of  and  operation  of  any  tax  treaties)  relating  to  the 
acquisition, ownership, and disposition of Common Shares. 

U.S. Holders Subject to Special U.S. Federal Income Tax Rules Not Addressed 

This summary does not address the U.S. federal income tax considerations applicable to U.S. Holders that are subject to 
special  provisions  under  the  Code,  including  (a) U.S.  Holders  that  are  tax-exempt  organizations,  qualified  retirement 
plans,  individual  retirement  accounts  or  other  tax-deferred  accounts;  (b) U.S.  Holders  that  are  financial  institutions, 
underwriters, insurance companies, real estate investment trusts or regulated investment companies or that are broker-
dealers, dealers, or traders in securities or currencies that elect to apply a mark-to-market accounting method; (c) U.S. 
Holders that have a “functional currency” other than the U.S. dollar; (d) U.S. Holders that own Common Shares as part 
of a straddle, hedging transaction, conversion transaction, constructive sale or other arrangement involving more than 
one position; (e) U.S. Holders that acquired Common Shares in connection with the exercise of employee stock options 
or  otherwise  as  compensation  for  services;  (f) U.S.  Holders  that  hold  Common  Shares  other  than  as  a  capital  asset 
(generally property held for investment purposes) within the meaning of Section 1221 of the Code; (g) U.S. Holders that 
are required to accelerate the recognition of any item of gross income with respect to Common Shares as a result of such 
income  being  recognized  on  an  applicable  financial  statement;  (h) U.S.  Holders  that  own,  directly,  indirectly  or  by 
attribution, 10% or more, by voting power or value, of the outstanding shares of the Company; (i) are partnerships and 
other pass-through entities (and investors in such partnerships and entities); (j) are U.S. expatriates or former long-term 
residents of the United States; or (k) are subject to taxing jurisdictions other than, or in addition to, the United States. 
U.S.  Holders  and  others  that  are  subject  to  special  provisions  under  the  Code,  including  U.S.  Holders  described 
immediately above, should consult their own tax advisors. 

If an entity that is classified as a partnership (or other “pass-through” entity) for U.S. federal income tax purposes holds 
Common Shares, the U.S. federal income tax consequences applicable to such partnership (or “pass-through” entity) and 
the partners of such partnership (or owners of such “pass-through” entity) generally will depend on the activities of the 
partnership (or “pass-through” entity) and the status of such partners (or owners). Partners of entities that are classified 
as partnerships (and owners of “pass-through” entities) for U.S. federal income tax purposes should consult their own 
tax advisors regarding the U.S. federal income tax consequences relating to the acquisition, ownership and disposition 
of Common Shares. 

Tax Consequences Other than U.S. Federal Income Tax Consequences Not Addressed 

This summary does not address the U.S. state and local, U.S. estate and gift,  U.S. federal net investment income, U.S. 
alternative  minimum  tax,  or  foreign  tax  consequences  to  U.S.  Holders  relating  to  the  acquisition,  ownership,  and 

85 

disposition of Common Shares. Each U.S. Holder should consult its own tax advisor regarding the U.S. state and local, 
U.S.  estate  and  gift,  U.S.  federal  net  investment  income,  U.S.  federal  alternative  minimum  tax  and  foreign  tax 
consequences relating to the acquisition, ownership, and disposition of Common Shares. 

U.S. Federal Income Tax Consequences of the Acquisition, Ownership and Disposition of Common Shares 

Distributions on Common Shares 

Subject to the PFIC rules discussed below, a U.S. Holder that receives a distribution, including a constructive distribution, 
with respect to a Common Share will be required to include the amount of such distribution in gross income as a dividend 
(without  reduction  for  any  Canadian  income  tax  withheld  from  such  distribution)  to  the  extent  of  the  current  or 
accumulated “earnings and profits” of the Company, as computed for U.S. federal income tax purposes. To the extent 
that a distribution exceeds the current and accumulated “earnings and profits” of the Company, such distribution will be 
treated first as a tax-free return of capital to the extent of a U.S. Holder’s tax basis in the Common Shares and thereafter 
as a gain from the sale or exchange of such Common Shares (see “Sale or Other Taxable Disposition of Common Shares” 
below). However, the Company does not intend to maintain the calculations of earnings and profits in accordance with 
U.S. federal income tax principles, and each U.S. Holder should therefore assume that any distribution by the Company 
with respect to the Common Shares will constitute ordinary dividend income. Subject to applicable limitations, dividends 
paid by the Company to non-corporate U.S. Holders, including individuals, generally will be eligible for the preferential 
tax rates applicable to long-term capital gains for dividends, provided certain holding period and other conditions are 
satisfied, including that the Company not be classified as a PFIC (as discussed below) in the tax year of distribution or in 
the  preceding  tax  year.  Dividends  received  on  Common  Shares  by  corporate  U.S.  Holders  will  not  be  eligible  for  the 
“dividends received deduction”. The dividend rules are complex, and each U.S. Holder should consult its own tax advisor 
regarding the application of such rules. 

Sale or Other Taxable Disposition of Common Shares 

Subject to the PFIC rules discussed below, upon the sale or other taxable disposition of Common Shares a U.S. Holder 
generally will recognize capital gain or loss in an amount equal to the difference between (a) the amount of cash plus 
the fair market value of any property received and (b) its tax basis in such Common Shares sold or otherwise disposed 
of. Such gain generally will be treated as “U.S. source” for purposes of applying the U.S. foreign tax credit rules unless 
the gain is subject to tax in Canada and is re-sourced as “foreign source” under the Convention and such U.S. Holder 
elects to treat such gain or loss as “foreign source” (see a more detailed discussion at “Foreign Tax Credit” below). Any 
such gain or loss generally will be capital gain or loss, which will be long-term capital gain or loss if, at the time of the 
sale or other disposition, such Common Shares are held for more than one year. Preferential tax rates apply to long-term 
capital gains of a U.S. Holder that is an individual, estate, or trust. There are currently no preferential tax rates for long-
term capital gains of a U.S. Holder that is a corporation. Deductions for capital losses are subject to significant limitations 
under the Code. 

Foreign Tax Credit 

Subject to the PFIC rules discussed below, a U.S. Holder that pays (whether directly or through withholding) Canadian 
income tax  with respect to dividends paid on Common Shares generally  will be  entitled, at the election of such U.S. 
Holder, to receive either a  deduction or a  credit for such Canadian income tax. Generally, a  credit  will reduce a  U.S. 
Holder’s U.S. federal income  tax liability on a dollar-for-dollar basis, whereas a  deduction will reduce a  U.S. Holder’s 
income that is subject to U.S. federal income tax. This election is made on a year-by-year basis and applies to all foreign 
taxes  paid  (whether  directly  or  through  withholding)  by  a  U.S.  Holder  during  a  year.  The  foreign  tax  credit  rules are 
complex and involve the application of rules that depend on a U.S. Holder’s particular circumstances. Accordingly, each 
U.S. Holder should consult its own U.S. tax advisors regarding the foreign tax credit rules. 

86 

Receipt of Foreign Currency 

The amount of any distribution paid in foreign currency to a U.S. Holder in connection with the ownership of Common 
Shares, or on the sale, exchange or other taxable disposition of Common Shares, generally will be equal to the U.S. dollar 
value  of  such  foreign  currency  based  on  the  exchange  rate  applicable  on  the  date  of  actual  or  constructive  receipt 
(regardless of whether such foreign currency is converted into U.S. dollars at that time). If the foreign currency received 
is not converted into U.S. dollars on the date of receipt, a U.S. Holder will have a basis in the foreign currency equal to 
its U.S. dollar value on the date of receipt. A U.S. Holder that receives foreign currency and converts such foreign currency 
into U.S. dollars at a conversion rate other than the rate in effect on the date of receipt may have a foreign currency 
exchange gain or loss, which generally would be treated as U.S. source ordinary income or loss for foreign tax credit 
purposes. Different rules apply to U.S. Holders who use the accrual method of tax accounting. U.S. Holders should consult 
their own U.S. tax advisors regarding the U.S. federal income tax consequences of receiving, owning and disposing of 
foreign currency. 

Passive Foreign Investment Company Rules 

If the Company is considered a PFIC within the meaning of Section 1297 of the Code at any time during a U.S. Holder’s 
holding  period,  then  certain  different  and  potentially  adverse  tax  consequences  would  apply  to  such  U.S.  Holder’s 
acquisition, ownership and disposition of Common Shares. 

PFIC Status of the Company 

The Company generally will be a PFIC if, for a given tax year, (a) 75% or more of the gross income of the Company for 
such tax year is passive income or (b) 50% or more of the assets held by the Company either produce passive income or 
are held for the production of passive income, based on the fair market value of such assets. “Gross income” generally 
includes all revenues less the cost of goods sold plus income from investments and from incidental or outside operations 
or sources, and “passive income” includes, for example, dividends, interest, certain rents and royalties, certain gains 
from the sale of stock and securities, and certain gains from commodities transactions. Active business gains arising from 
the  sale  of  commodities  generally  are  excluded  from  passive  income  if  substantially  all  of  a  foreign  corporation’s 
commodities are stock in trade or inventory, depreciable property used in a trade or business, or supplies regularly used 
or consumed in a trade or business, and certain other requirements are satisfied. 

For purposes of the PFIC income test and asset test described above, if the Company owns, directly or indirectly, 25% or 
more of the total value of the outstanding shares of another corporation, the Company will be treated as if it (a) held a 
proportionate share of the assets of such other corporation and (b) received directly a proportionate share of the income 
of such other corporation. In addition, for purposes of the PFIC income test and asset test described above, “passive 
income” does not include any interest, dividends, rents or royalties that are received or accrued by the Company from a 
“related person” (as defined in Section 954(d)(3) of the Code), to the extent such items are properly allocable to the 
income of such related person that is not passive income. 

Under certain attribution rules, if the Company is a PFIC, U.S. Holders will be deemed to own their proportionate share 
of any subsidiary of the Company which is also a PFIC (a “Subsidiary PFIC”), and will be subject to U.S. federal income tax 
on (a) a distribution on the shares of a Subsidiary PFIC and (b) a disposition of shares of a Subsidiary PFIC, both as if the 
U.S. Holder directly held the shares of such Subsidiary PFIC. 

The Company believes that it was not a PFIC for the tax years ended November 30, 2015, 2016, 2017, 2020 and 2021. 
The Company believes it was a PFIC for the tax years ended November 30, 2018, 2019 and 2022 and may be a PFIC in 
future tax years. No opinion of legal counsel or ruling from the IRS concerning the status of the Company as a PFIC has 
been obtained or is currently planned to be requested. The determination of whether the Company (or a subsidiary of 
the Company) was, or will be, a PFIC for a tax year depends, in part, on the application of complex U.S. federal income 
tax rules, which are subject to differing interpretations. In addition, whether the Company (or subsidiary) will be a PFIC 
for any tax year depends on the assets and income of the Company (and each such subsidiary) over the course of each 

87 

such tax year and, as a result, cannot be predicted with certainty as of the date of this document. Accordingly, there can 
be no assurance that the IRS will not challenge any determination made by the Company (or subsidiary) concerning its 
PFIC status or that the Company (and any subsidiary) was not, or will not be, a PFIC for any tax year. U.S. Holders should 
consult their own tax advisors regarding the PFIC status of the Company and any subsidiary of the Company. 

Default PFIC Rules under Section 1291 of the Code 

If the Company is a PFIC, the U.S. federal income tax consequences to a U.S. Holder of the acquisition, ownership and 
disposition of Common Shares will depend on whether such U.S. Holder makes a QEF election or makes a mark-to-market 
election under Section 1296 of the Code (a “Mark-to-Market Election”) with respect to Common Shares. A U.S. Holder 
that does not make either a QEF Election or a Mark-to-Market Election will be referred to in this summary as a “Non-
Electing U.S. Holder”. 

A Non-Electing U.S. Holder will be subject to the rules of Section 1291 of the Code with respect to (a) any gain recognized 
on the sale or other taxable disposition of Common Shares and (b) any excess distribution paid on the Common Shares. 
A  distribution  generally  will  be  an  “excess  distribution”  to  the  extent  that  such  distribution  (together  with  all  other 
distributions  received  in  the  current  tax  year)  exceeds  125%  of  the  average  distributions  received  during  the  three 
preceding tax years (or during a U.S. Holder’s holding period for the Common Shares, if shorter). 

If the Company is a PFIC, under Section 1291 of the Code any gain recognized on the sale or other taxable disposition of 
Common Shares (including an indirect disposition of shares of a Subsidiary PFIC), and any excess distribution paid on 
Common Shares (or a distribution by a Subsidiary PFIC to its shareholder that is deemed to be received by a U.S. Holder) 
must be ratably allocated to each day of a Non-Electing U.S. Holder’s holding period for the Common Shares. The amount 
of any such gain or excess distribution allocated to the tax year of disposition or excess distribution and to years before 
the Company became a PFIC, if any, would be taxed as ordinary income. The amounts allocated to any other tax year 
would be subject to U.S. federal income tax at the highest tax applicable to ordinary income in each such year, and an 
interest charge would be imposed on the tax liability for each such year, calculated as if such tax liability had been due 
in each such year. A Non-Electing U.S. Holder that is not a corporation must treat any such interest paid as “personal 
interest”, which is not deductible. 

If the Company is a PFIC for any tax year during which a Non-Electing U.S. Holder holds Common Shares, the Company 
will continue to be treated as a PFIC with respect to such Non-Electing U.S. Holder, regardless of whether the Company 
ceases to be a PFIC in one or more subsequent years. If the Company ceases to be a PFIC, a Non-Electing U.S. Holder may 
terminate this deemed PFIC status with respect to Common Shares by electing to recognize gain (which will be taxed 
under the rules of Section 1291 of the Code discussed above) as if such Common Shares were sold on the last day of the 
last tax year for which the Company was a PFIC. 

Under proposed Treasury Regulations, if a U.S. Holder has an option, warrant or other right to acquire stock of a PFIC, 
such option, warrant or right is considered to be PFIC stock subject to the default rules of Section 1291 of the Code. 
Under rules described below, if the Company was a PFIC, the holding period for the option, warrant or other right would 
begin  on  the  day  after  the  date  a  U.S.  Holder  acquired  the  option,  warrant  or  other  right.  This  would  impact  the 
availability of the QEF Election and Mark-to-Market Election with respect to an option, warrant or other right. Thus, a 
U.S. Holder would have to account for an option, warrant or other right and Common Shares under the PFIC rules and 
the applicable elections differently (see discussion below under “QEF Election” and “Market-to-Market Election”.) 

QEF Election 

In the event the Company is a PFIC and a U.S. Holder makes a QEF Election for the first tax year in which its holding period 
of its Common Shares begins, such U.S. Holder generally  will not be subject to the rules of Section 1291 of the Code 
discussed above with respect to its Common Shares. However, a U.S. Holder that makes a QEF Election will be subject to 
U.S. federal income tax on such U.S. Holder’s pro rata share of (a) the net capital gain of the Company, which will be 
taxed as long-term capital gain to such U.S. Holder, and (b) the ordinary earnings of the Company, which will be taxed as 

88 

ordinary income to such U.S. Holder. Generally, “net capital gain” is the excess of (a) net long-term capital gain over 
(b) net short-term capital gain, and “ordinary earnings” are the excess of (a) “earnings and profits” over (b) net capital 
gain. A U.S. Holder that makes a QEF Election will be subject to U.S. federal income tax on such amounts for each tax 
year in which the Company is a PFIC, regardless of whether such amounts are actually distributed to such U.S. Holder by 
the  Company.  However,  a  U.S.  Holder  that  makes  a  QEF  Election  may,  subject  to  certain  limitations,  elect  to  defer 
payment of current U.S. federal income tax on such amounts, subject to an interest charge. If such U.S. Holder is not a 
corporation, any such interest paid will be treated as “personal interest”, which is not deductible. 

A U.S. Holder that makes a QEF Election generally (a) may receive a tax-free distribution from the Company to the extent 
that such distribution represents “earnings and profits” of the Company that were previously included in income by the 
U.S. Holder because of such QEF Election and (b) will adjust such U.S. Holder’s tax basis in the Common Shares to reflect 
the amount included in income or allowed as a tax-free distribution because of such QEF Election. In addition, a U.S. 
Holder that makes a QEF Election generally will recognize capital gain or loss on the sale or other taxable disposition of 
Common Shares. 

The procedure for making a QEF Election, and the U.S. federal income tax consequences of making a QEF Election, will 
depend on whether such QEF Election is timely. A QEF Election will be treated as “timely” if it is made for the first year 
in the U.S. Holder’s holding period for the Common Shares in which the Company was a PFIC. A U.S. Holder may make a 
timely QEF Election by filing the appropriate QEF Election documents at the time such U.S. Holder files a U.S. federal 
income tax return for such year. 

A QEF Election will apply to the tax year for which such QEF Election is made and to all subsequent tax years, unless such 
QEF Election is invalidated or terminated or the IRS consents to revocation of such QEF Election. If a U.S. Holder makes 
a QEF Election and, in a subsequent tax year, the Company ceases to be a PFIC, the QEF Election will remain in effect 
(although it will not be applicable) during those tax years in which the Company is not a PFIC. Accordingly, if the Company 
becomes a PFIC in a subsequent tax year, the QEF Election will be effective, and the U.S. Holder will be subject to the 
QEF rules described above during a subsequent tax year in which the Company qualifies as a PFIC. 

As discussed above, under proposed Treasury Regulations, if a U.S. Holder has an option, warrant or other right to acquire 
stock of a PFIC, such option, warrant or right is considered to be PFIC stock subject to the default rules of Section 1291 
of the Code on its disposition. However, a holder of an option, warrant or other right to acquire stock of a PFIC may not 
make  a  QEF  Election  that  will  apply  to  the  option,  warrant  or  other  right  to  acquire  PFIC  stock.  In  addition,  under 
proposed Treasury Regulations, if a U.S. Holder holds an option, warrant or other right to acquire stock of a PFIC, the 
holding period with respect to shares of stock of the PFIC acquired upon exercise of such option, warrant or other right 
will include the period that the option, warrant or other right was held. U.S. Holders should consult their own tax advisors 
regarding the application of the PFIC rules to Common Shares. 

The Company will make available to U.S. Holders, upon their written request, information as to its status as a PFIC,  as 
reasonably determined by the Company, and will provide to a U.S. Holder all information and documentation that a U.S. 
Holder making a QEF Election with respect to the Company is required to obtain for U.S. federal income tax purposes in 
the event it is a PFIC. However, U.S. Holders should be aware that the Company can provide no assurances that it will 
provide any such information relating to any Subsidiary PFIC. Because the Company may own shares in one or more 
Subsidiary PFICs and may acquire shares in one or more Subsidiary PFICs in the future, they will continue to be subject 
to the rules discussed above with respect to the taxation of gains and excess distributions with respect to any Subsidiary 
PFIC for which the U.S. Holders do not obtain the required information to file a QEF Election. U.S. Holders should consult 
their own tax advisor regarding the availability of, and procedure for making, a QEF Election with respect to the Company 
and any Subsidiary PFIC. 

Mark-to-Market Election 

A  U.S.  Holder  may  make  a  Mark-to-Market  Election  only  if  the  Common  Shares  are  marketable  stock.  The  Common 
Shares  generally  will  be  “marketable  stock”  if  they  are  regularly  traded  on  (a) a  national  securities  exchange  that  is 

89 

registered  with  the  SEC;  (b) the  national  market  system  established  pursuant  to  section  11A  of  the  Securities  and 
Exchange Act of 1934; or (c) a foreign securities exchange that is regulated or supervised by a governmental authority of 
the country in which the market is located, provided that (i) such foreign exchange has trading volume, listing, financial 
disclosure and other requirements and the laws of the country in which such foreign exchange is located, together with 
the rules of such foreign exchange, ensure that such requirements are actually enforced; and (ii) the rules of such foreign 
exchange ensure active trading of listed stocks. If such stock is traded on such a qualified exchange or other market, such 
stock  generally  will  be  “regularly  traded”  for  any  calendar  year  during  which  such  stock  is  traded,  other  than  in  de 
minimus quantities, on at least 15 days during each calendar quarter. Each U.S. Holder should consult its own tax advisor 
regarding whether the Common Shares constitute marketable stock. 

A U.S. Holder that makes a Mark-to-Market Election with respect to its Common Shares generally will not be subject to 
the  rules of  Section 1291  of  the  Code  discussed  above.  However,  if  a  U.S.  Holder  does  not  make  a  Mark-to-Market 
Election beginning in the first tax year of such U.S. Holder’s holding period for Common Shares or such U.S. Holder has 
not made a timely QEF Election, the rules of Section 1291 of the Code discussed above will apply to certain dispositions 
of, and distributions on, the Common Shares. 

A  U.S.  Holder  that  makes  a  Mark-to-Market  Election  will  include  in  ordinary  income,  for  each  tax  year  in  which  the 
Company is a PFIC, an amount equal to the excess, if any, of (a) the fair market value of the Common Shares, as of the 
close of such tax year over (b) such U.S. Holder’s tax basis in such Common Shares. A U.S. Holder that makes a Mark-to-
Market Election will be allowed a deduction in an amount equal to the excess, if any, of (i) such U.S. Holder’s adjusted 
tax basis in the Common Shares over (ii) the fair market value of such Common Shares (but only to the extent of the net 
amount of previously included income as a result of the Mark-to-Market Election for prior tax years). 

U.S. Holders that make a Mark-to-Market  Election generally also will adjust their tax basis in the Common Shares to 
reflect the amount  included in gross income or allowed as a  deduction because of such Mark-to-Market  Election. In 
addition, upon a sale or other taxable disposition of Common Shares, a U.S. Holder that makes a Mark-to-Market Election 
will recognize ordinary income or loss (not to exceed the excess, if any, of (a) the amount included in ordinary income 
because of such Mark-to-Market Election for prior tax years over (b) the amount allowed as a deduction because of such 
Mark-to-Market Election for prior tax years). 

A Mark-to-Market Election applies to the tax year in which such Mark-to-Market Election is made and to each subsequent 
tax year, unless the Common Shares cease to be “marketable stock” or the IRS consents to revocation of such election. 
U.S. Holders should consult their own tax advisors regarding the availability of, and procedure for making, a Mark-to-
Market Election. 

Although a U.S. Holder may be eligible to make a Mark-to-Market Election with respect to Common Shares, no such 
election may be made with respect to the stock of any Subsidiary PFIC that a U.S. Holder is treated as owning because 
such stock is not marketable. Hence, the Mark-to-Market Election will not be effective to eliminate the interest charge 
described above with respect to deemed dispositions of Subsidiary PFIC stock or distributions from a Subsidiary PFIC. 

Other PFIC Rules 

Under Section 1291(f) of the Code, the IRS has issued proposed Treasury Regulations that, subject to certain exceptions, 
would cause a U.S. Holder that had not made a timely QEF Election to recognize gain (but not loss) upon certain transfers 
of  Common  Shares  that  would  otherwise  be  tax-deferred  (e.g.,  gifts  and  exchanges  pursuant  to  corporate 
reorganizations) in the event the Company is a PFIC during such U.S. Holder’s holding period for the relevant shares. 
However, the specific U.S. federal income tax consequences to a U.S. Holder may vary based on the manner in which 
Common Shares are transferred. 

Certain additional adverse rules will apply with respect to a U.S. Holder if the Company is a PFIC, regardless of whether 
such  U.S.  Holder  makes  a  QEF  Election.  For  example,  under  Section 1298(b)(6) of  the  Code,  a  U.S.  Holder  that  uses 

90 

Common Shares as security for a loan will, except as may be provided in Treasury Regulations, be treated as having made 
a taxable disposition of such Common Shares. 

In any year in which the Company is classified as a PFIC, a U.S. Holder will be required to file an annual report with the 
IRS containing such information as Treasury Regulations and/or other  IRS guidance may require. U.S. Holders should 
consult their own tax advisors regarding the requirements of filing such information returns under these rules, including 
the requirement to file an IRS Form 8621. 

In addition, a U.S. Holder who acquires Common Shares from a decedent will not receive a “step up” in tax basis of such 
Common Shares to fair market value unless such decedent had a timely and effective QEF Election in place. 

Special rules also apply to the amount of foreign tax credit that a U.S. Holder may claim on a distribution from a PFIC. 

The PFIC rules are complex, and U.S. Holders should consult their own tax advisors regarding the PFIC rules and how they 
may affect the U.S. federal income tax consequences of the acquisition, ownership, and disposition of Common Shares 
in the event the Company is a PFIC at any time during such holding period for such Common Shares. 

Information Reporting, Backup Withholding Tax 

Certain  U.S.  Holders  are  required  to  report  information  relating  to  an  interest  in  Common  Shares  subject  to  certain 
exceptions (including an exception for Common Shares held in accounts maintained by certain financial institutions), by 
attaching a completed IRS Form 8938, Statement of Specified Foreign Financial Assets, with their tax return for each year 
in  which  they  hold  an  interest  in  Common  Shares.  U.S.  Holders  should  consult  their  own  tax  advisors  regarding 
information reporting requirements relating to their ownership of Common Shares. 

Payments made within the United States, or by a U.S. payor or U.S. middleman, of dividends on Common Shares, and 
proceeds  arising  from  certain  sales  or  other  taxable  dispositions  of  Common  Shares,  may  be  subject  to  information 
reporting and backup withholding tax, at the rate of 24%, if a U.S. Holder (a) fails to furnish such U.S. Holder’s correct 
U.S.  social  security  or  other  taxpayer  identification  number  (generally  on  Form W-9);  (b) furnishes  an  incorrect  U.S. 
taxpayer identification number; (c) is notified by the IRS that such U.S. Holder has previously failed to properly report 
items subject to backup withholding tax; or (d) fails under certain circumstances to certify, under penalty of perjury, that 
such U.S. Holder has furnished its correct U.S. taxpayer identification number and that the IRS has not notified such U.S. 
Holder that it is subject to backup withholding tax. However, U.S. Holders that are corporations generally are excluded 
from these information reporting and backup withholding tax rules. Backup withholding is not an additional tax. Any 
amounts withheld under the U.S. backup withholding tax rules will be allowed as a credit against a U.S. Holder’s U.S. 
federal income tax liability, if any, or will be refunded, if such U.S. Holder timely furnishes the required information to 
the IRS. U.S. Holders should consult their own tax advisors regarding the information reporting and backup withholding 
tax rules. 

Item 6. Selected Financial Data 

NA 

91 

 
 
 
 
Item 7.    MANAGEMENT’S DISCUSSION AND ANALYSIS OF FINANCIAL CONDITION 

AND RESULTS OF OPERATIONS 

General 

This Management’s Discussion and Analysis (“MD&A”) of Trilogy Metals Inc. (“Trilogy”, “the Company”, “us” or “we”) is 
dated February 13, 2023 and provides an analysis of our audited financial results for the year ended November 30, 2022 
compared  to  the  year  ended  November 30,  2021.  A  discussion  of  our  year  ended  November  30,  2022  compared  to 
November 30, 2021 is contained in our report on Form 10-K for the year ended November 30, 2022. 

The  following  information  should  be  read  in  conjunction with  our  November 30, 2022  audited  consolidated  financial 
statements  and  related  notes  which  were  prepared  in  accordance  with  United  States  generally  accepted  accounting 
principles  (“U.S. GAAP”).  A  summary  of  the  U.S. GAAP  accounting  policies  is  outlined  in  note 2  of  the  audited 
consolidated  financial  statements.  All  amounts  are  in  United  States  dollars  unless  otherwise  stated.  References  to 
“Canadian dollars” and “C$” and “CDN$” are to the currency of Canada and references to “U.S. dollars”, “$” or “US$” are 
to the currency of the United States. 

These consolidated financial statements have been prepared on a going concern basis which assumes that the Company 
will be able to realize its assets and discharge its liabilities in the normal course of business for the foreseeable future.  
As  at  November  30,  2022,  the  Company  had  a  working  capital  surplus  of  $2.4  million  (2021  -  $5.6  million)  and  an 
accumulated deficit of $66.9 million (2021 - $42.6 million).  The Company has no recurring source of cash inflows at its 
current stage.  The Company’s cash outflow from operations was $3.9 million for the year ended November 30, 2022.  
The Company intends to finance its future requirements through a combination of debt and/or equity issuance.  There 
is no assurance that the Company will be able to obtain such financings or obtain them on a favourable terms.  These 
uncertainties raise substantial doubt about the Company’s ability to continue as a going concern. 

Richard  Gosse,  P.  Geo,  VP  Exploration  of  the  Company,  is  a  Qualified  Person  under  National  Instrument  43-101 
- Standards of Disclosure for Mineral Projects (“NI 43-101”), and has approved the scientific and technical information in 
this MD&A. 

Trilogy’s  shares  are  listed  on the  Toronto  Stock  Exchange  (“TSX”)  and  the  NYSE  American  under  the  symbol  “TMQ”. 
Additional  information  related  to  Trilogy,  including  our  annual  report  on  Form 10-K,  is  available  on  SEDAR 
at www.sedar.com and on EDGAR at www.sec.gov. 

Description of business 

We are a base metals exploration company focused on the exploration and development of mineral properties, through 
our equity investee, in the Ambler mining district located in Alaska, U.S.A. We conduct our operations through a wholly 
owned subsidiary, NovaCopper US Inc. which is doing business as Trilogy Metals US (“Trilogy Metals US”). Our Upper 
Kobuk Mineral Projects, (“UKMP” or “UKMP Projects”) were contributed into a 50/50 joint venture (the “Joint Venture”) 
named Ambler Metals LLC (“Ambler Metals”) between Trilogy and South32 Limited (“South32”) on February 11, 2020 
(see below). The projects contributed to Ambler Metals consist of: i) the Ambler lands which host the Arctic copper-zinc-
lead-gold-silver project (the “Arctic Project”); and ii) the Bornite lands being explored under a collaborative long-term 
agreement  with  NANA  Regional  Corporation,  Inc.  (“NANA”),  a  regional  Alaska  Native  Corporation,  which  hosts  the 
Bornite carbonate-hosted copper project (the “Bornite Project”) and related assets. The Company also conducts early-
stage exploration through a wholly owned subsidiary, 995 Exploration Inc. 

Property review 

The UKMP Projects are held by our equity investee, Ambler Metals of which Trilogy holds a 50% interest. The projects 
are located in the Ambler mining district in Northwest Alaska. The UKMP Projects comprise approximately 448,217 acres 
(181,387 hectares) consisting of the Ambler and Bornite lands.  

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On  October  19,  2011,  NANA  Regional  Corporation,  Inc.  (“NANA”),  an  Alaska  Native  Corporation  headquartered  in 
Kotzebue, Alaska, and Trilogy Metals US entered an Exploration Agreement and Option Agreement (as amended, the 
“NANA Agreement”) for the  cooperative development  of NANA’s respective resource interests in the Ambler mining 
district  of Northwest  Alaska.  Upon the formation of Ambler Metals, the  Company assigned its rights and obligations 
under the NANA Agreement to Ambler Metals.  The NANA Agreement consolidates Ambler Metals’ and NANA’s land 
holdings into an approximately 142,831-hectare land package and provides a framework for the exploration and any 
future development of this high-grade and prospective poly-metallic belt. 

The NANA Agreement establishes a framework for any future development of either the Bornite Project or the Arctic 
Project.  Both projects are included as part  of a  larger area  of interest  set  forth in the  NANA Agreement.   Upon the 
decision to proceed with development of a mine within the area of interest, inclusive of the Arctic and Bornite Projects, 
NANA maintains the right to purchase an ownership interest in the mine equal to between 16%-25% or retain a 15% net 
proceeds royalty which is payable after we have recovered certain historical costs, including capital and cost of capital. 
Should NANA elect to purchase an ownership interest in the mine, consideration will be payable based on the elected 
percentage purchased and all the costs incurred on the properties less $40.0 million, not to be less than zero. The parties 
would form a joint venture and be responsible for all future costs incurred in connection with the mine, including capital 
costs of the mine, based on each party’s pro-rata share. 

NANA would also be granted a net smelter return royalty between 1% and 2.5% upon the execution of a mining lease or 
a  surface  use  agreement,  the  amount  of  which  is  determined  by  the  particular  area  of  land  from  which  production 
originates. 

Arctic Project 

The Ambler lands, which host a number of deposits, including the high-grade copper-zinc-lead-gold-silver Arctic Project, 
and other mineralized occurrences within a 100-kilometer-long volcanogenic massive sulfide (“VMS”) belt. The Ambler 
lands are located in Northwestern Alaska and consist  of 185,805 acres (75,192 hectares) of Federal patented mining 
claims which hosts the Arctic deposit and State of Alaska mining claims which we are actively exploring, within which 
VMS mineralization has been found. 

Prior to the formation of the Joint Venture on February 11, 2020, we had recorded the Ambler lands as a mineral property 
with acquisition costs capitalized and exploration costs expensed in accordance with our accounting policies. 

Bornite Project 

On October 19, 2011, Trilogy Metals US and NANA signed a collaborative agreement to explore and develop the Ambler 
mining  district.  Under  the  Exploration  Agreement  and  Option  to  Lease  (as  amended,  the  “NANA  Agreement”),  we 
acquired, in exchange for, among other things, a $4.0 million cash payment to NANA, the exclusive right to explore the 
Bornite  property  and  lands  deeded  to  NANA  through  the  Alaska  Native  Claims  Settlement  Act  (“ANCSA”),  located 
adjacent to the Arctic Project, and the non-exclusive right to access and entry onto NANA’s lands. The amounts paid to 
NANA were recorded as acquisition costs for the Bornite Project. 

Prior to the formation of the Joint Venture on February 11, 2020, we had accounted for the Bornite property as a mineral 
property with acquisition costs capitalized and exploration costs expensed in accordance with our accounting policies. 

Joint venture 

On February 11, 2020, pursuant to a contribution agreement among Trilogy and South32, Trilogy contributed all its assets 
associated with the UKMP, including the Arctic and Bornite Projects in exchange for a 50% membership interest in Ambler 
Metals.  Simultaneously, South32 contributed $145 million cash in exchange for a 50% membership interest in Ambler 
Metals. 

93 

Ambler Metals is an independently operated company, jointly controlled by Trilogy and South32 through a four-member 
board of which two members are currently appointed by Trilogy based on its 50% equity interest. All significant decisions 
related to the UKMP require the approval of both companies. We determined that Ambler Metals is a variable interest 
entity, or VIE, because it is expected to need additional funding from its owners for its significant activities. However, we 
concluded that we are not the primary beneficiary of Ambler Metals as the power to direct its activities, through its 
board, is shared under the limited liability company agreement. As we have significant influence over Ambler Metals 
through our representation on its board, we use the equity method of accounting for our investment in Ambler Metals. 
Our investment in Ambler Metals was initially measured at its fair value of $176 million upon recognition. Our maximum 
exposure  to  loss  in  this  entity  is  limited  to  the  carrying  amount  of  our  investment  in  Ambler  Metals,  which,  as  of 
November 30, 2022, totaled $142.8 million.  

Upper Kobuk Mineral Project activities 

Ambler Metals spent approximately $28.5 million during the fiscal year, which was mainly spent on the summer drilling 
program.  Field season activities at the UKMP commenced in late May, with the camp opening on May 20 and drilling 
was  completed  on  September  16.    The  field  program  included  10,738  meters  of  diamond  drilling  that  prioritized 
advancing  the  Arctic  Project  with  additional  infill  drilling  to  further  improve  the  confidence  in  the  resource  and  the 
completion of a geotechnical study to further de-risk the project.  Exploration outside of the Arctic deposit focused on 
identifying copper-rich satellite deposits near Arctic in the VMS Belt and Cosmos Hills. 

For the 2022 Arctic field program, Ambler Metals completed 8,376 meters in 47 holes as part of an 8,400-meter infill 
program to increase confidence of the resource from the Indicated to Measured category. This includes five holes totaling 
815  meters  completed  for  the  geotechnical  assessment  of  Arctic  that  was  initiated  last  year  and  two  infill  holes 
instrumented for the ongoing geohydrological assessment. 

The 2022 exploration program for the Cosmos Hills and Ambler VMS Belt includes drilling of 7 holes totaling 2,363 meters 
as well as detailed mapping and soil sampling to build on the work performed during the prior year. In addition, 1,350 
meters of trenching was completed around Pardner Hill. 

On November 29, 2022, Trilogy announced the first set of drilling results from the first seven drill holes of the Arctic 
drilling, AR22-0191 through to AR22-0197, which include four infill holes and three geotechnical holes (AR22-0194, 0196 
and 0197)1. All drill holes are sized HQ3 (63.5 mm diameter). Results indicate mineralization is reasonably continuous. 

Ambler Mining District Industrial Access Project (“AMDIAP” or “Ambler Access Project”) 

During the summer of 2020, the United States Bureau of Land Management ("BLM") issued the Joint Record of Decision 
("JROD") for the AMDIAP. Lawsuits were filed shortly thereafter by a coalition of national and Alaska environmental non-
government organizations in response to the BLM's issuance of the JROD for the Ambler Access Project. 

On January 6, 2021, BLM, the National Park Service and AIDEA signed Right-of-Way agreements giving AIDEA the ability 
to cross federally owned and managed lands along the route for the Ambler Access Project approved in the JROD. The 
authorizing documents with the two agencies are the final federal permits required for the Ambler Access Project.   

During the second quarter of 2021, AIDEA signed a land access agreement with Doyon Limited to conduct feasibility and 
permitting activities to advance the Ambler Access Project and in September 2021 AIDEA signed a land access agreement 
with NANA Regional Corporation, Inc. to conduct similar activities. 

1 See press released dated November 29, 2022, titled “Trilogy Metals Announces First Results of the 2022 Arctic Drill 
Program at the Upper Kobuk Mineral Projects”. 

94 

 
On  February  22,  2022,  the  United  States  Department  of  the  Interior  (“DOI”)  filed  a  motion  to  remand  the  Final 
Environmental Impact Statement and suspend the right-of-way permits issued to AIDEA for the Ambler Access Project 
and in mid-March, the BLM and DOI suspended the right-of-way grant and the right-of-way permit over federal lands. 

On  September  20,  2022,  the  BLM  published  in  the  Federal  Register  a  Notice  of  Intent  (“NOI”)  that  it  will  prepare  a 
Supplemental Environmental Impact Statement (“SEIS”) for the proposed Ambler Mining District Industrial Access Road.  
The BLM anticipates publishing a draft SEIS during the second quarter of calendar year 2023 and a final SEIS within the 
fourth quarter of calendar year 2023. 

Outlook 

The Company has approved a budget for Ambler Metals for fiscal 2023 in the amount of $9.2 million for advancing the 
UKMP and $1.0 million for the Ambler Access Project of which the entire amount is funded by the Joint Venture.  Ambler 
Metals had $80.8 million of cash as at the fiscal year end on November 30, 2022.  The main focus of this year’s budget is 
to support advancing engineering efforts and resource estimation at the Arctic Project along with preparations for the 
submission of mine permits. 

The Company has approved a 2023 cash budget for corporate, head office, activities of approximately $4.0 million (2022 
-  $5.5  million).    The  corporate  budget  consists  of  personnel  and  related  costs  of  $0.9  million  (2022  -  $2.1  million), 
professional fees of $1.5 million (2022 - $0.9 million), investor relations and marketing costs of $0.2 million ( 2022 - $0.6 
million), office related costs of $0.4 million (2022 - $0.5 million), insurance costs of $0.6 million (2022  - $0.5 million), 
regulatory  costs  of  $0.3  million  (2022  -  $0.3  million)  and  exploration  activities  of  $0.1  million  (2022  -  $0.15  million).   
Trilogy had $2.6 million of cash at the fiscal year end on November 30, 2022.  The Company intends to finance its future 
requirements through a combination of debt and/or equity issuance. 

Summary of results 

Selected expenses 
Exploration expense 
General and administrative 
Investor relations 
Professional fees 
Salaries 
Salaries and directors expense – stock-based compensation 
Gain on disposition of mineral property  
Share of loss on equity investment 
Comprehensive loss for the year 
Basic and diluted loss per common share 

Year ended   
  November 30,    
2022   

$       

in thousands of dollars, 
except for per share amounts 
Year ended   
  November 30,    
2021   
$    
 143    
 1,517   
 602   
 818   
 2,007   
 3,472   
 —   
 13,082   
 (21,660)  
 (0.15)  

 47   
 1,287   
 183   
 998   
 984   
 3,427   
 (84)  
 17,360   
 (24,257)  
 (0.17)  

For  the year ended November 30, 2022, we reported a  net  loss of $24.3 million (or $0.17 basic and diluted loss per 
common share) compared to a net loss of $21.7 million (or $0.15 basic and diluted loss per common share) in fiscal 2021. 
The $2.6 million increase in comprehensive loss in the current year, when compared to fiscal 2021, is due to the increase 
in our share of losses of Ambler Metals of $4.3 million partially offset from overall savings of $1.7 million in general and 
administrative expenses, investor relations, professional fees and salaries when compared to prior fiscal year 2021.  The 
increase in our share of losses of Ambler Metals of $4.3 million is mainly due to an increase in mineral property expenses 
over  the  comparative  to  prior  fiscal  year  2021  from  higher  drilling  and  project  support  cost  as  well  as  higher  pre-
development costs for the Ambler Access Project. 

95 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
      
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
    
 
    
    
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Fourth quarter results 

For the fourth quarter of 2022, there was a $0.7 million reduction in expenses compared to the fourth quarter of 2021.  
When comparing the fourth quarter of 2022 with the fourth quarter of 2021, professional fees increased by $0.2 million 
due to additional engineering costs related to updating our technical reports; salaries and related costs reduced by $0.8 
million  due  to  staffing  reductions  and  timing  of  year-end  incentive  payouts;  and  investor  relations  and  general  and 
administration reduced by $0.1 million due to cash preservation efforts.  Our share of losses of Ambler Metals for the 
fourth quarter of 2022 is comparable to the fourth quarter of 2021.  

Selected financial data 

Annual information  

The following annual information is prepared in accordance with U.S. GAAP. 

Interest income 
Services agreement income 
Expenses 
Comprehensive loss for the year 
Total assets 
Total liabilities 

Quarterly information 

Year ended    

in thousands of dollars 
Year ended   
    November 30,      November 30,    
2021   
$    
 16   
 22   
 8,616   
 (21,660)  
 167,305   
 1,266   

2022    
$       
 34    
 —    
 6,925    
 (24,257)    
 145,995     
 567     

  Q4 2022     Q3 2022     Q2 2022   Q1 2022 
  11/30/22     08/31/22     05/31/22   02/28/22 
$       
 11    
 —     
 1,166    

$       
 19    
 —     
 1,176    

$    
 2  
 —  
 1,468  

 2 
 — 
 3,115 

   Q4 2021 
   11/30/21     08/31/21 
$       

$       

in thousands of dollars, 
except per share amounts 
   Q3 2021     Q2 2021     Q1 2021  
   05/31/21     02/28/21  
$    
$       
 5  
 5    
 —  
 —     
 3,401  
 1,718    

$       
 4    
 130     
 1,596    

 2 
 13 
 1,879 

 —    

 (84)    

 —  

 — 

 — 

 —    

 —    

 —  

 4,065    
 —    
 (5,222)     

 8,925    
 (58)    
 (9,938)     

 2,460  
 119  
 (4,074)  

 1,910 
 29 
 (5,023)     

 4,190 
 — 
 (6,067)     

 6,072    
 —    
 (7,664)     

 1,700    
 —    
 (3,413)     

 1,120  
 —  
 (4,516)  

 (0.04)     

 (0.07)     

 (0.03)  

 (0.03)     

 (0.05)     

 (0.05)     

 (0.02)     

 (0.03)   

Interest and other income 
Exploration expense 
Operating expenses 
Gain on disposition of mineral 
property 
Share of loss on equity 
investment 
Write off of mineral properties   
Loss for the period 
Loss per common share – basic 
and diluted 

Factors  that  can  cause  fluctuations  in  our  quarterly  results  include  the  length  of  the  exploration  field  season  at  the 
properties, the type of program conducted, and stock-based compensation expensing. Subsequent to the formation of 
the Joint Venture, project related costs may cause fluctuations in our quarterly results through our 50% share of the Joint 
Venture’s net operating loss. 

For  the fourth quarter of 2022, we reported a  comprehensive loss of $5.2 million, which consisted of $1.2 million in 
operating expenses and $4.1 million for Trilogy's 50% share of Ambler Metals’ operating loss. Operating expenses for the 
fourth quarter of 2022 consisted of work being done on updating technical reports for the Arctic and Bornite Projects.  

96 

 
 
 
 
 
 
 
 
 
      
 
   
 
 
   
 
   
   
   
   
   
    
    
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
 
 
    
 
 
 
   
 
  
  
  
   
   
 
  
  
 
  
  
 
  
  
  
  
  
  
 
For  the  third  quarter  of  2022,  we  reported  a  comprehensive  loss  of  $9.9  million,  which  consisted  of  $1.0  million  in 
operating expenses and $8.9 million for Trilogy’s 50% share of Ambler Metals’ operating loss.  In the third quarter of 
2021, we reported a comprehensive loss of $7.7 million, which consisted of $1.6 million in operating expenses and $6.1 
million for Trilogy’s 50% share of Ambler Metals’ operating loss. The increase in our share of losses of Ambler Metals was 
mainly due to an increase in mineral property expenses from higher drilling and project support costs as well as higher 
pre-development costs for the Ambler Access Project. 

For the second quarter of 2022, we reported a comprehensive loss of $4.1 million, which consisted of $1.5 million in 
operating expenses, $2.5 million for Trilogy’s 50% share of Ambler Metals’ operating loss and $0.1 million in mineral 
properties that were written off during the quarter.  In the second quarter of 2021, we recognized a comprehensive loss 
of $3.4 million which consisted of $1.7 million in operating expenses and $1.7 million for Trilogy’s share of Ambler Metals’ 
operating loss. When compared to the second quarter of 2021, our pro rata share of the Joint Venture’s operating loss 
is $0.8 million higher for the second quarter of 2022. The increase is primarily due to increased funding for the Ambler 
Access Project (the “AAP”), engineering and project related salaries and wages in comparison to the second quarter of 
2021. The $0.2 million decrease in operating expenses for the current period versus the comparative is primarily due to 
cost savings strategies implemented during the period after management review of discretionary items in general and 
administrative expenses, investor relations and professional fees. Furthermore, during the second quarter of 2022, in an 
effort to preserve cash, the executive team received stock-based compensation in lieu of salaries. 

For  the  first  quarter  of  2022,  we  reported  a  comprehensive  loss  of  $5.0  million,  which  consisted  of  $3.1  million  in 
operating expenses and $1.9 million for Trilogy’s 50% share of Ambler Metals’ operating loss. In the first quarter of 2021, 
we reported a comprehensive loss of $4.5 million which consisted of $3.4 million in operating expenses and $1.1 million 
for Trilogy’s share of Ambler Metals’ operating loss. When compared to the first quarter of 2021, our pro rata share of 
the Joint Venture’s operating loss was $0.8 million higher for the first quarter of 2022 as it included  pre-development 
costs incurred by Ambler Metals for the Ambler Access Project. The $0.3 million decrease in operating expenses for the 
first quarter of 2022 versus the comparative was primarily due to a decrease of $0.2 million in stock-based compensation 
during  the  first  quarter  of  2022.  The  remaining  $0.1  million  in  cost  reduction  was  spread  over  the  general  and 
administrative, investor relations, professional fees and salaries cost categories. 

Liquidity and capital resources 

We expended $3.9 million on operating activities during the 2022 fiscal year with the majority of cash spent on corporate 
salaries, professional fees related to our annual regulatory filings, annual insurance renewal, annual fees paid to the 
Toronto Stock Exchange and the NYSE American Exchange and with the American and Canadian securities commissions. 

At November 30, 2022, we had $2.6 million in cash and working capital of $2.4 million. Management continues with cash 
preservation strategies to reduce cash expenditures where feasible, including but not limited to reductions in marketing 
and investor conferences and office expenses.  In addition, the Company’s Board of Directors have agreed to take all of 
their fees in shares of the Company in an effort to preserve cash and increase share ownership.  The Company’s senior 
management team are also taking a portion of their base salaries in shares of the Company to preserve cash.   

All project related costs are funded by the Joint Venture.  Ambler Metals is well funded to advance the UKMP with $80.8 
million in cash and $77.7 million in working capital as at  November 30,  2022. There are sufficient  funds at the Joint 
Venture to fund an operating budget of $9.2 million and $1.0 million for the Ambler Access Project for fiscal 2023. Trilogy 
does  not  anticipate  having  to  fund  the  activities  of  Ambler  Metals  until  the  current  cash  balance  $80.8  million  is 
expended. 

Future cash requirements may vary materially from current  expectations. The Company will need to raise additional 
funds in the future to support its operations and administration expenses. Future sources of liquidity are likely in the 
form of an equity financing but may include debt financing, convertible debt, exercise of options, or other means. The 

97 

 
 
continued operations of the Company are dependent on its ability to obtain additional financing or to generate future 
cash flows. 

There is no assurance that the Company will be able to obtain such financings or obtain them on favourable terms.  These 
uncertainties rise substantial doubt about the Company’s ability to continue as a going concern. 

Off-balance sheet arrangements 

We have no material off-balance sheet arrangements. 

Outstanding share data 

At  February 14,  2023,  we  had  148,722,699  common  shares  issued  and  outstanding.  At  February 14,  2023,  we  had 
13,585,400 stock options outstanding with a weighted-average exercise price of CDN$2.18 and 2,260,734 Deferred Share 
Units (“DSUs”) and 1,610,638 Restricted Share Units (“RSUs”) outstanding. At February 14, 2023 we hold 9,293 NovaGold 
Resources Inc. (“NovaGold”) DSUs for which the NovaGold director is entitled to receive one common share of Trilogy 
for every six NovaGold shares to be received upon their retirement from the NovaGold board. A total of 1,549 common 
shares will be issued upon redemption of the NovaGold DSUs. For additional information on NovaGold DSUs, please refer 
to note 9 in our November 30, 2022 audited consolidated financial statements. Upon the exercise of all the forgoing 
convertible securities, the Company would be required to issue an aggregate of 17,458,321 common shares. 

Financial instruments 

Our financial instruments consist of cash, accounts receivable, deposits, accounts payable and accrued liabilities. The fair 
value of the financial instruments approximates their carrying value due to the short-term nature of their maturity. Our 
financial instruments initially measured at fair value and then held at amortized cost include cash, accounts receivable, 
deposits, and accounts payable and accrued liabilities.  

(a)  Currency risk 

Currency risk is the risk of a fluctuation in financial asset and liability settlement amounts due to a change in foreign 
exchange rates. The Company operates in the United States and Canada. The Company’s exposure to currency risk at 
November 30, 2022 is limited to Canadian dollar balances consisting of cash of CDN$223,000, accounts receivable of 
CDN$22,000 and certain trade payables and accrued personnel costs CDN$393,000. Based on a 10% change in the US-
Canadian  exchange  rate,  assuming  all  other  variables  remain  constant,  the  Company’s  net  loss  would  change  by 
approximately $10,000. 

(b)  Credit risk 

Credit  risk  is  the  risk  of  an  unexpected  loss  if  a  customer  or  third  party  to  a  financial  instrument  fails  to  meet  its 
contractual obligations. The Company holds cash with Canadian chartered financial institutions. The Company’s accounts 
receivable are for the value added tax credit. The Company’s exposure to credit risk is equal to the balance of cash and 
accounts receivable as recorded in the financial statements. 

(c)  Liquidity risk 

Liquidity risk is the risk that we will encounter difficulties raising funds to meet our financial obligations as they fall due. 
We  are  in  the  exploration  stage  and  do  not  have  cash  inflows  from  operations;  therefore,  we  manage  liquidity  risk 
through the management of our capital structure and financial leverage. Future sources of liquidity may arise from equity 
financing, debt financing, convertible debt, or other means.  

98 

(d)  Interest rate risk 

Interest rate risk is the risk that the fair value or future cash flows of a financial instrument will fluctuate because of 
changes in market interest rates. The Company is exposed to interest rate risk with respect to interest earned on cash. 
Based on balances as at November 30, 2022, a 1% change in interest rates would result in a change in a negligible change 
in net loss, assuming all other variables remain constant. 

As we are currently in the exploration phase none of our financial instruments are exposed to commodity price risk; 
however,  our  ability  to  obtain  long-term  financing  and  its  economic  viability  could  be  affected  by  commodity  price 
volatility. 

New accounting pronouncements 

There were no new accounting pronouncements requiring management consideration during fiscal year 2022. 

Critical accounting estimates 

The most  critical accounting estimates upon which  our financial status depends are those requiring estimates of the 
recoverability  of  our  equity  method  investment  in  Ambler  Metals  LLC,  income  taxes  and  valuation  of  stock-based 
compensation. 

Impairment of Investment in Ambler Metals LLC 

Management  assesses the possibility of impairment  in the carrying value of its  equity method investment  in Ambler 
Metals whenever events or circumstances indicate that the carrying amount of the investment may not be recoverable. 
Significant  judgments  are  made  in  assessing  the  possibility  of  impairment.  Factors  that  may  be  indicative  of  an 
impairment include a loss in the value of an investment that is not temporary. Management considers several factors in 
considering if an indicator of impairment has occurred, including but not limited to, sustained losses by the investment, 
the absence of the ability to recover the carrying amount of the investment, significant changes in the legal, business or 
regulatory  environment,  significant  adverse  changes  impacting  the  investee  and  internal  reporting  indicating  the 
economic performance of an investment is, or will be, worse than expected. 

These factors are subjective and require consideration at each period end. If an indicator of impairment is determined 
to exist, the fair value of the impaired investment is determined based on the valuation of cohort companies with similar 
projects or upon the present value of expected future cash flows using discount rates and other assumptions believed 
to be consistent with those used by principal market participants and observed market earnings multiples of comparable 
companies. 

Management  calculates the  estimated undiscounted future net  cash flows relating to  the asset  or asset  group using 
estimated  future  prices,  proven  and  probable  reserves  and  other  mineral  resources,  and  operating,  capital  and 
reclamation costs. When the carrying value of an asset exceeds the related undiscounted cash flows, the asset is written 
down  to  its  estimated  fair  value,  which  is  usually  determined  using  discounted  future  cash  flows.  Management’s 
estimates  of  mineral  prices,  mineral  resources,  foreign  exchange  rates,  production  levels  operating,  capital  and 
reclamation costs are subject to risk and uncertainties that may affect the determination of the recoverability of the 
long-lived asset. It is possible that material changes could occur that may adversely affect management’s estimates. 

Income taxes 

We must make estimates and judgments in determining the provision for income tax expense, deferred tax assets and 
liabilities, and liabilities for unrecognized tax benefits including interest and penalties. We are subject to income tax law 
in the United States and Canada. The evaluation of tax liabilities involving uncertainties in the application of complex tax 
regulation  is  based  on  factors  such  as  changes  in  facts  or  circumstances,  changes  in  tax  law,  new  audit  activity,  and 

99 

effectively settled issues. The evaluation of an uncertain tax position requires significant judgment, and a change in such 
judgement would result in an additional charge to the income tax expense and liability. 

Stock-based compensation 

Compensation expense for options granted to employees, directors and certain service providers is determined based 
on estimated fair values of the options at the time of grant using the Black-Scholes option pricing model, which takes 
into  account,  as  of  the  grant  date,  the  fair  market  value  of  the  shares,  expected  volatility,  expected  life,  expected 
forfeiture rate, expected dividend yield and the risk-free interest rate over the expected life of the option. The use of the 
Black-Scholes option pricing model requires input estimation of the expected life of the option, volatility, and forfeiture 
rate which can have a significant impact on the valuation model, and resulting expense recorded. 

Disclosure controls and procedures 

Disclosure controls and procedures are designed to ensure that information required to be disclosed in reports filed or 
submitted  by  the  Company  under  U.S.  and  Canadian  securities  legislation  is  recorded,  processed,  summarized  and 
reported  within  the  time  periods  specified  in  those  rules,  including  providing  reasonable  assurance  that  material 
information is gathered and reported to senior management, including the Chief Executive Officer (“CEO”) and Chief 
Financial Officer (“CFO”), as appropriate, to permit timely decisions regarding public disclosure. Management, including 
the CEO and CFO, has evaluated the effectiveness of the design and operation of the Company’s disclosure controls and 
procedures, as defined in Rule 13a-15(e) and 15d-15(e) of  the U.S. Exchange Act and the rules of Canadian Securities 
Administrators, as at November 30, 2022. Based on this evaluation, the CEO and CFO have concluded that the Company’s 
disclosure controls and procedures were effective as at November 30, 2022. 

Internal control over financial reporting 

Management is responsible for establishing and maintaining adequate internal control over financial reporting as defined 
in Rule 13a-15(f) and 15d-15(f) of the U.S. Exchange Act and National Instrument 52-109 Certification of Disclosure in 
Issuer’s Annual and Interim filings. Any system of internal control over financial reporting, no matter how well designed, 
has  inherent  limitations.  Therefore,  even  those  systems  determined  to  be  effective  can  provide  only  reasonable 
assurance with respect to financial statement preparation and presentation. Management has used the Committee of 
Sponsoring Organizations of the Treadway Commission in Internal Control – Integrated Framework (2013) to evaluate 
the effectiveness of the Company’s internal control over financial reporting. Based on this assessment, management has 
concluded that as at November 30, 2022, the Company’s internal control over financial reporting was effective. 

Risk factors 

Trilogy and its future business, operations and financial condition are subject to various risks and uncertainties due to 
the  nature  of  its  business  and  the  present  stage  of  exploration  of  its  mineral  properties.  Certain  of  these  risks  and 
uncertainties are under the heading “Risk Factors” under Trilogy’s Form 10-K dated February 14, 2023 available on SEDAR 
at www.sedar.com and EDGAR at www.sec.gov and on our website at www.trilogymetals.com. 

Additional information 

Additional  information  regarding  the  Company,  including  our  annual  report  on  Form 10-K,  is  available  on  SEDAR 
at www.sedar.com and EDGAR at www.sec.gov and on our website at www.trilogymetals.com. 

100 

Cautionary notes 

Forward-looking statements 

This Management’s Discussion and Analysis contains “forward-looking information” and “forward-looking statements” 
within  the  meaning  of  Section  27A  of  the  U.S.  Securities  Act  of  1933,  as  amended,  Section  21E  of  the  U.S.  Securities 
Exchange Act of 1934, as amended (the “Exchange Act”), and other applicable securities laws. These forward-looking 
statements may include statements regarding the Company’s work programs and budgets; perceived merit of properties, 
exploration results and budgets, the Company and Ambler Metals’ funding requirements, mineral reserves and resource 
estimates, work programs, capital expenditures, operating costs, cash flow estimates, production estimates and similar 
statements relating to the economic viability of a project, timelines, strategic plans, statements regarding Ambler Metals’ 
plans and expectations relating to its Upper Kobuk Mineral Projects, sufficiency of the Ambler Metals’ cash to fund the 
UKMP;  impact  of  COVID-19  on  the  Company’s  operations;  market  prices  for  precious  and  base  metals;  statements 
regarding  the  Ambler  Road  Project;  or  other  statements  that  are  not  statements  of  fact.  These  statements  relate  to 
analyses and other information that are based on forecasts of future results, estimates of amounts not yet determinable 
and assumptions of management. Statements concerning mineral resource estimates may also be deemed to constitute 
“forward-looking statements” to the extent that they involve estimates of the mineralization that will be encountered if 
the property is developed. 

Any statements that express or involve discussions with respect to predictions, expectations, beliefs, plans, projections, 
objectives, assumptions or future events or performance (often, but not always, identified by words or phrases such as 
“expects”,  “is  expected”,  “anticipates”,  “believes”,  “plans”,  “projects”,  “estimates”,  “assumes”,  “intends”,  “strategy”, 
“goals”, “objectives”, “potential”, “possible” or variations thereof or stating that certain actions, events, conditions or 
results “may”, “could”, “would”, “should”, “might” or “will” be taken, occur or be achieved, or the negative of any of 
these terms and similar expressions) are not statements of historical fact and may be forward-looking statements. 

Forward-looking  statements  are  based  on  the  beliefs,  expectations  and  opinions  of  management  on  the  date  the 
statements are made, as well as on a number of material assumptions, which could prove to be significantly incorrect, 
including about: 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

our ability to achieve production at the Upper Kobuk Mineral Projects; 

the accuracy of our mineral resource and reserve estimates; 

the results, costs and timing of future exploration drilling and engineering; 

timing and receipt of approvals, consents and permits under applicable legislation; 

the adequacy of our financial resources; 

the receipt of third party contractual, regulatory and governmental approvals for the exploration, development, 
construction and production of our properties and any litigation or challenges to such approvals; 

our expected ability to develop adequate infrastructure and that the cost of doing so will be reasonable; 

continued good relationships with South32, our joint venture partner, as well as local communities and other 
stakeholders; 

there being no significant disruptions affecting operations, whether relating to labor, supply, power damage to 
equipment or other matter; 

expected trends and specific assumptions regarding metal prices and currency exchange rates; 

the potential impact of the novel coronavirus (COVID-19); and 

prices for and availability of fuel, electricity, parts and equipment and other key supplies remaining consistent 
with current levels. 

101 

We have also assumed that no significant events will occur outside of our normal course of business. Although we have 
attempted to identify important factors that could cause actual actions, events or results to differ materially from those 
described in forward-looking statements, there may be other factors that cause actions, events or results not to be as 
anticipated, estimated  or  intended.  We  believe  that  the  assumptions  inherent  in  the  forward-looking  statements  are 
reasonable as of the date of this MD&A. However, forward-looking statements are not guarantees of future performance 
and, accordingly, undue reliance should not be put on such statements due to the inherent uncertainty therein. 

Forward-looking statements are subject to a variety of known and unknown risks, uncertainties and other factors that 
could cause actual events or results to differ from those reflected in the forward-looking statements, including, without 
limitation: 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

risks related to the COVID-19 pandemic; 

risks related to inability to define proven and probable reserves; 

risks  related  to  our  ability  to  finance  the  development  of our  mineral  properties  through  external  financing, 
strategic alliances, the sale of property interests or otherwise; 

uncertainty as to whether there will ever be production at the Company’s mineral exploration and development 
properties; 

risks  related  to  our  ability  to  commence  production  and  generate  material  revenues  or  obtain  adequate 
financing for our planned exploration and development activities; 

risks related to lack  of infrastructure including but  not  limited to the risk  whether or not  the Ambler Mining 
District Industrial Access Project, or AMDIAP, will receive the requisite permits and, if it does, whether the Alaska 
Industrial Development and Export Authority will build the AMDIAP; 

risks related to inclement weather which may delay or hinder exploration activities at our mineral properties; 

risks related to our dependence on a third party for the development of our projects; 

none of the Company’s mineral properties are in production or are under development; 

commodity price fluctuations; 

uncertainty related to title to our mineral properties; 

our history of losses and expectation of future losses; 

risks related to increases in demand for equipment, skilled labor and services needed for exploration and 

development of mineral properties, and related cost increases; 

uncertainties relating to the assumptions underlying our resource estimates, such as metal pricing, metallurgy, 
mineability, marketability and operating and capital costs; 

uncertainty related to inferred mineral resources; 

•  mining and development risks, including risks related to infrastructure, accidents, equipment breakdowns, labor 
disputes or other unanticipated difficulties with or interruptions in development, construction or production; 

• 

• 

risks and uncertainties relating to the interpretation of drill results, the geology, grade and continuity of our 
mineral deposits; 

risks related to governmental regulation and permits, including environmental regulation, including the risk that 
more stringent requirements or standards may be adopted or applied due to circumstances unrelated to the 
Company and outside of our control; 

102 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

the  risk  that  permits  and  governmental  approvals  necessary  to  develop  and  operate  mines  at  our  mineral 
properties will not be available on a timely basis or at all; 

risks related to the need for reclamation activities on our properties and uncertainty of cost estimates related 
thereto; 

risks related to the acquisition and integration of operations or projects; 

our need to attract and retain qualified management and technical personnel; 

risks related to conflicts of interests of some of our directors and officers; 

risks related to potential future litigation; 

risks related to market events and general economic conditions; 

risks related to future sales or issuances of equity securities decreasing the value of existing Trilogy common 

shares, diluting voting power and reducing future earnings per share; 

risks related to the voting power of our major shareholders and the impact that a sale by such shareholders may 
have on our share price; 

uncertainty as to the volatility in the price of the Company’s common shares; 

the Company’s expectation of not paying cash dividends; 

adverse  federal  income  tax  consequences  for  U.S.  shareholders  should  the  Company  be  a  passive  foreign 
investment company; 

risks related to global climate change; 

risks related to adverse publicity from non-governmental organizations; 

uncertainty as to our ability to  maintain  the adequacy of internal control over financial reporting as per the 
requirements of Section 404 of the Sarbanes-Oxley Act; and 

increased regulatory compliance costs, associated with rules and regulations promulgated by the United States 
Securities and Exchange Commission, Canadian Securities Administrators, the NYSE American, the Toronto Stock 
Exchange, and the Financial Accounting Standards Boards, and more specifically, our efforts to comply with the 
Dodd-Frank Wall Street Reform and Consumer Protection Act. 

This list  is not  exhaustive of the factors that  may affect  any of the Company’s forward-looking statements. Forward-
looking  statements  are  statements  about  the  future  and  are  inherently  uncertain,  and  actual  achievements  of  the 
Company  or  other  future  events  or  conditions  may  differ  materially  from  those  reflected  in  the  forward-looking 
statements due to a variety of risks, uncertainties and other factors, including, without limitation, those referred to in 
Trilogy’s Form 10-K dated February 14, 2023, filed with the Canadian securities regulatory authorities and the SEC, and 
other information released by Trilogy and filed with the appropriate regulatory agencies. 

The Company’s forward-looking statements are based on the beliefs, expectations and opinions of management on the 
date the statements are made, and the Company does not assume any obligation to update forward-looking statements 
if circumstances or management’s beliefs, expectations or opinions should change, except as required by law. For the 
reasons set forth above, investors should not place undue reliance on forward-looking statements 

. 

103 

 
Item 7A.  QUANTITATIVE AND QUALITATIVE DISCLOSURES ABOUT MARKET RISK 

Not applicable. 

Item 8.     FINANCIAL STATEMENTS AND SUPPLEMENTARY DATA 

Supplementary Data 

For the required supplementary data, please see the section heading “Item 7. Management’s Discussion and Analysis of 
Financial Condition and Results of Operations” above. 

Management’s Report on Internal Control over Financial Reporting 

The management of Trilogy Metals Inc. is responsible for establishing and maintaining adequate internal control over 
financial  reporting  under  Rule 13a-15(f) and  15d-15(f) of  the  U.S.  Exchange  Act.  The  Securities  Exchange  Act  of  1934 
defines  this  as  a  process  designed  by,  or  under  the  supervision  of,  the  Company’s  principal  executive  and  principal 
financial  officers  and  effected  by  the  Company’s  Board  of  Directors,  management  and  other  personnel,  to  provide 
reasonable  assurance  regarding  the  reliability  of  financial  reporting  and  the  preparation  of  financial  statements  for 
external  purposes  in  accordance  with  generally  accepted  accounting  principles  in  the  United  States  of  America,  and 
includes those policies and procedures that: 

• 

• 

• 

pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions 
and dispositions of the assets of the Company; 

provide reasonable assurance that transactions are recorded as necessary to permit preparation of financial 
statements in accordance with generally accepted accounting principles in the United States of America, and 
that  receipts  and  expenditures  of  the  Company  are  being  made  only  in  accordance  with  authorizations  of 
management and directors of the Company; and 

provide  reasonable  assurance  regarding  prevention  or  timely  detection  of  unauthorized  acquisition,  use  or 
disposition of the Company’s assets that may have a material effect on the consolidated financial statements. 

Because of its inherent limitations, internal control over financial reporting may not prevent or detect misstatements. 
Projections of any evaluation of effectiveness to future periods are subject to risk that controls may become inadequate 
because of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate. 

Management assessed the effectiveness of the Company’s internal control over financial reporting as of November 30, 
2022. In making this assessment, the Company’s management used the criteria set forth by the Committee of Sponsoring 
Organizations of the Treadway Commission in Internal Control – Integrated Framework (2013). 

Based  upon  our  assessment  and  those  criteria,  management  concluded  that  the  Company’s  internal  control  over 
financial reporting is effective as of November 30, 2022. 

/s/ Tony Giardini 

     /s/ Elaine Sanders 

Tony Giardini 
President, Chief Executive Officer & Director 

   Elaine Sanders 
   Vice President & Chief Financial Officer 

February 13, 2023 

104 

 
  
     
  
     
     
 
 
 
 
Report of Independent Registered Public Accounting Firm 

To the Shareholders and Board of Directors of Trilogy Metals Inc. 

Opinion on the Financial Statements 
We have audited the accompanying consolidated balance sheets of Trilogy Metals Inc. and its subsidiaries (together, the 
Company)  as  of  November  30,  2022  and  2021,  and  the  related  consolidated  statements  of  earnings  (loss)  and 
comprehensive earnings (loss), changes in shareholders’ equity and cash flows for each of the three years in the period 
ended November 30, 2022, including the related notes (collectively referred to as the consolidated financial statements). 
In our opinion, the consolidated financial statements present fairly, in all material respects, the financial position of the 
Company as of November 30, 2022 and 2021, and the results of its operations and its cash flows for each of the three 
years in the period ended November 30, 2022 in conformity with accounting principles generally accepted in the United 
States of America. 

Substantial Doubt About the Company’s Ability to Continue as a Going Concern 
The accompanying consolidated financial statements have been prepared assuming that the Company will continue as a 
going concern. As discussed in Note 1 to the consolidated financial statements, the Company incurred recurring losses 
from  operations  and  negative  cash  flows  from  operating  activities  that  raise  substantial  doubt  about  its  ability  to 
continue as a going concern. Management’s plans in regard to these matters are also described in Note 1. The financial 
statements do not include any adjustments that might result from the outcome of this uncertainty. 

Basis for Opinion 
These consolidated financial statements are the responsibility of the Company’s management. Our  responsibility is to 
express an opinion on the Company’s consolidated financial statements based on our audits. We are a public accounting 
firm registered with the Public Company Accounting Oversight Board (United States) (PCAOB) and are required to be 
independent with respect to the Company in accordance with the U.S. federal securities laws and the applicable rules 
and regulations of the Securities and Exchange Commission and the PCAOB. 

We conducted our audits of these consolidated financial statements in accordance with the standards of the PCAOB. 
Those  standards  require  that  we  plan  and  perform  the  audit  to  obtain  reasonable  assurance  about  whether  the 
consolidated financial statements are free of material misstatement, whether due to error or fraud. The Company is not 
required to have, nor were we engaged to perform, an audit of its internal control over financial reporting. As part of our 
audits we are required to obtain an understanding of internal control over financial reporting but not for the purpose of 
expressing an opinion on the effectiveness of the Company’s internal control over financial reporting. Accordingly, we 
express no such opinion. 

Our audits included performing procedures to assess the risks of material misstatement of the consolidated financial 
statements, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures 
included  examining,  on  a  test  basis,  evidence  regarding  the  amounts  and  disclosures  in  the  consolidated  financial 
statements.  Our  audits  also  included  evaluating  the  accounting  principles  used  and  significant  estimates  made  by 
management, as well as evaluating the overall presentation of the consolidated financial statements. We believe that 
our audits provide a reasonable basis for our opinion. 

Critical Audit Matters  
The  critical  audit  matter  communicated  below  is  a  matter  arising  from  the  current  period  audit  of  the  consolidated 
financial statements that was communicated or required to be communicated to the audit committee and that (i) relates 
to  accounts  or  disclosures  that  are  material  to  the  consolidated  financial  statements  and  (ii)  involved  our  especially 
challenging, subjective, or complex judgments. The communication of critical audit matters does not alter in any way our 
opinion on the consolidated financial statements, taken as a whole, and we are not, by communicating the critical audit 

105 

 
matter below, providing a separate opinion on the critical audit matter or on the accounts or disclosures to which it 
relates. 

Assessment of impairment indicators related to the Investment in Ambler Metals LLC 

As described in Notes 2 and 4 to the consolidated financial statements, the Company has an investment in Ambler Metals 
LLC (“Ambler”) accounted for using the equity method of accounting. As of November 30, 2022, the carrying amount of 
the  Company’s  investment  in  Ambler  was  $142.8  million.  Management  assesses  impairment  indicators  whenever 
changes  in  facts  and  circumstances  indicate  there  is  an  other  than  temporary  loss  in  value  of  the  investment. 
Management applies judgment in assessing whether facts and circumstances indicate an other than temporary loss in 
value has occurred that could give rise to the requirement to conduct an impairment test. Factors such as (i) sustained 
losses  by  the  investment,  (ii)  an  absence  of  the  ability  to  recover  the  carrying  amount  of  the  investment,  and  (iii) 
deterioration of market conditions, are evaluated by management in determining whether there are any indicators of 
impairment. 

The principal considerations for our determination that performing procedures relating to the assessment of impairment 
indicators related to the investment in Ambler is a critical audit matter are that there was judgment by management 
when assessing whether indicators of impairment exist, specifically related to assessing: (i) an absence of the ability to 
recover the investment in Ambler, and (ii) a deterioration of market conditions. This in turn led to a high degree of auditor 
judgment  and  subjectivity  in performing  procedures  to  evaluate  audit  evidence  relating  to  the  judgements  made  by 
management in their assessment of indicators of impairment related to the investment in Ambler. 

Addressing the matter involved performing procedures and evaluating audit evidence in connection with forming our 
overall  opinion  on  the  consolidated  financial  statements.  These  procedures  included,  among  others,  evaluating  the 
reasonableness of management’s assessment of indicators of impairment related to the investment in Ambler, which 
included (i) evaluating whether there was an absence of the ability to recover the carrying amount of the investment by 
considering changes in Trilogy Metals market capitalization, and (ii) evaluating whether there  was a  deterioration of 
market conditions and assessing the completeness of facts and circumstances that could be considered as impairment 
indicators of the Investment in Ambler by performing an audit of the financial statements of Ambler as of November 30, 
2022. Performing an audit of the financial statements of Ambler as of November 30, 2022 included (i) evaluating whether 
there were significant adverse changes in the business climate including significant decreases in copper, zinc, and other 
metal  prices  (ii)  evaluating  whether  there  were  significant  adverse  changes  in  legal  factors  with  respect  to  mineral 
property  title  matters,  and  (iii)  evaluating  whether  there  was  an  accumulation  of  costs  significantly  in  excess  of  the 
amount originally expected for the acquisition or construction of  Ambler’s mineral properties. 

/s/PricewaterhouseCoopers LLP 

Chartered Professional Accountants 
Vancouver, Canada 
February 13, 2023 

We have served as the Company's auditor since 2012. 

106 

 
 
Trilogy Metals Inc. 
Consolidated Balance Sheets 
As at November 30, 2022 and 2021 

                                               in thousands of US dollars  
      November 30, 2022         November 30, 2021  
$         

$     

Assets 
Current assets 
Cash 
Accounts receivable  (note 3) 
Deposits and prepaid amounts 
Total current assets 

Investment in Ambler Metals LLC  (note 4) 
Fixed assets  (note 5) 
Mineral properties  (note 6) 
Right of use asset  (note 8 (a)) 
Total assets 

Liabilities 
Current liabilities 
Accounts payable and accrued liabilities  (note 7) 
Current portion of lease liability 
Total current liabilities 

Long-term portion of lease liability  (note 8 (b)) 
Total liabilities 

Shareholders’ equity 
Share capital (note 9) – unlimited common shares authorized, 
no par value Issued – 146,225,035 (2021 – 145,009,811) 
Contributed surplus 
   Contributed surplus – options  (note 9(a)) 
   Contributed surplus – units  (note 9(b)) 
Deficit 

Total shareholders' equity 
Total liabilities and shareholders' equity 

Commitments and contingencies (note 13) 
Subsequent events (note 14) 

 2,573   
 17   
 320   
 2,910   

 142,754  
 12   
 —   
 319  
 145,995   

 345   
 189  
 534   

 33  
 567   

 182,178   
 122   
 27,352   
 2,638   
 (66,862)   
 145,428   
 145,995   

 6,308 
 19 
 285 
 6,612 

 160,063 
 29 
 119 
 482 
 167,305 

 852 
 179 
 1,031 

 235 
 1,266 

 180,820 
 122 
 25,990 
 1,712 
 (42,605)   
 166,039 
 167,305 

(See accompanying notes to the consolidated financial statements) 

/s/Tony Giardini, President, CEO and Director 

/s/ Kalidas Madhavpeddi, Director 

Approved on behalf of the Board of Directors    

107 

 
 
 
 
 
 
 
 
 
 
 
    
 
       
     
 
     
 
     
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
   
 
     
 
     
 
     
 
     
 
 
 
 
 
 
 
 
 
 
 
  
 
   
 
 
 
 
 
 
 
 
  
 
   
 
     
 
     
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
  
  
  
  
  
 
Trilogy Metals Inc. 
Consolidated Statements of Earnings (Loss) and Comprehensive Earnings (Loss) 
For the Years Ended November 30 

in thousands of US dollars, except share and per share amounts   
2020   
$    

$        

2022 

2021 

$       

Expenses 
Amortization 
Exploration expenses 
Feasibility study (note 6(d)) 
Foreign exchange (gain) loss 
General and administrative 
Investor relations 
Mineral properties expense (note 6(d)) 
Professional fees 
Salaries 
Salaries – technical services (note 4(e)) 
Salaries and directors expense – stock-based compensation 
Total expenses 
Other items 
Gain on disposition of mineral property 
Interest and other income 
Services agreement income (note 4(e)) 
Share of loss on equity investment (note 4(b)) 
Write off mineral properties 
Comprehensive (loss) earnings for the year 
Basic (loss) earnings per common share  
Diluted (loss) earnings per common share  
Basic weighted average number of common shares 
outstanding 
Diluted weighted average number of common shares 
outstanding 

 17 
 47 
 — 
 (18) 
 1,287 
 183 
 — 
 998 
 984 
 — 
 3,427 
 6,925 

 (84) 
 (34) 
 — 
 17,360 
 90 
 (24,257) 
 (0.17) 
 (0.17) 

 21 
 143 
 — 
 36 
 1,517 
 602 
 — 
 818 
 2,007 
 — 
 3,472 
 8,616 

 — 
 (16) 
 (22) 
 13,082 
 — 
 (21,660) 
 (0.15) 
 (0.15) 

 91  
 —  
 1,065  
 56  
 1,650  
 537  
 1,545  
 1,347  
 1,411  
 898  
 3,564  
 12,164  

 (175,770)  
 (87)  
 (929)  
 2,855  
 —  
 161,767  
 1.14  
 1.12  

 145,721,736 

 144,428,926 

 141,464,877  

 145,721,736 

 144,428,926 

 144,604,750  

(See accompanying notes to the consolidated financial statements) 

108 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
   
 
 
 
 
 
      
  
 
   
     
   
     
  
  
 
     
     
  
 
  
 
  
 
  
 
  
 
  
 
  
 
     
     
  
 
     
     
  
 
     
     
  
 
     
     
  
 
     
     
  
 
     
     
  
 
  
 
  
 
  
 
     
     
  
 
     
     
  
 
   
     
   
     
    
  
 
     
     
  
 
     
     
  
 
     
     
  
 
  
 
  
 
  
 
  
 
  
 
  
 
     
     
  
 
  
 
  
 
  
 
  
 
  
 
  
 
  
 
  
 
  
 
  
 
  
 
 
 
 
Trilogy Metals Inc. 
Consolidated Statements of Changes in Shareholders’ Equity 
For the Years Ended November 30 

  Number of shares 

   Share capital 

  Contributed 
surplus 

     in thousands of US dollars, except share amounts 
Total    
    shareholders’    

   Contributed 
surplus –  
options 

   Contributed 
surplus –  
units 

Deficit 

equity 

$     

 18,263   
 217   
 —   
 3,564   
 161,767   
 183,811   
 416   
 3,472   
 (21,660)  
 166,039   
 54   
 —   
 51   
 114   
 3,427   
 (24,257)  
 145,428   

Balance – 2019 
Exercise of options 
Restricted share units 
Stock-based compensation 
Earnings for the year 
Balance – 2020 
Exercise of options 
Stock-based compensation 
Loss for the year 
Balance – 2021 
Exercise of options 
Restricted share units 
Joint venture contribution 
Services settled by common shares 
Stock-based compensation 
Loss for the year 
Balance – 2022 

outstanding        
 140,427,761 
 3,297,588 
 412,501 
 — 
 — 
 144,137,850 
 871,961 
 — 
 — 
 145,009,811 
 81,674 
 992,081 
 31,469 
 110,000 
 — 
 — 
 146,225,035 

$            

$        

$        

$        

$        

 177,971 
 1,133 
 642 
 — 
 — 
 179,746 
 1,074 
 — 
 — 
 180,820 
 76 
 1,117 
 51 
 114 
 — 
 — 
 182,178 

 122 
 — 
 — 
 — 
 — 
 122 
 — 
 — 
 — 
 122 
 — 
 — 
 — 
 — 
 — 
 — 
 122 

 21,123 
 (916) 
 — 
 3,096 
 — 
 23,303 
 (658) 
 3,345 
 — 
 25,990 
 (22) 
 — 
 — 
 — 
 1,384 
 — 
 27,352 

 1,759 
 — 
 (642) 
 468 
 — 
 1,585 
 — 
 127 
 — 
 1,712 
 — 
 (1,117) 
 — 
 — 
 2,043 
 — 
 2,638 

 (182,712) 
 — 
 — 
 — 
 161,767 
 (20,945) 
 — 
 — 
 (21,660) 
 (42,605) 
 — 
 — 
 — 
 — 
 — 
 (24,257) 
 (66,862) 

(See accompanying notes to the consolidated financial statements) 

109 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
     
  
 
 
  
     
  
 
 
 
  
 
   
  
  
  
 
 
  
 
  
  
  
  
 
 
     
  
  
      
   
   
   
  
  
  
  
 
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
 
  
  
  
  
  
  
      
   
   
   
  
  
  
      
   
   
   
  
  
  
  
 
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
 
  
  
  
  
  
  
      
   
   
   
  
 
  
  
 
  
  
  
  
 
  
  
 
  
  
  
  
 
  
  
 
  
  
  
  
 
  
  
 
  
  
  
  
 
  
  
 
  
  
  
  
 
  
  
 
  
  
  
  
 
  
  
 
  
  
  
  
 
 
 
Trilogy Metals Inc. 
Consolidated Statements of Cash Flows 
For the Years Ended November 30 

in thousands of US dollars   
2020   
$    

2021    
$       

2022    
$       

Cash flows used in operating activities 
 (Loss) earnings for the year 
Adjustments to reconcile net loss to cash flows in operating activities 

Amortization 
Professional fees settled by common shares 
Office lease accounting 
Loss on working capital written-off upon joint venture formation 
Gain on disposal of mineral property  
Loss on equity investment in Ambler Metals LLC (note 4(b)) 
Unrealized foreign exchange (gain) loss 
Stock-based compensation 
Write off mineral properties 

Net change in non-cash working capital 

Decrease in accounts receivable 
Decrease (Increase) in deposits and prepaid amounts 
Decrease in accounts payable and accrued liabilities 

Total cash flows used in operating activities 
Cash flows from financing activities 
Proceeds from exercise of options 
Total cash flows from financing activities 
Cash flows from investing activities 
Mineral claims 
Proceeds from disposition of mineral property 
Total cash flows from (used in) investing activities 
Decrease in cash  
Effect of exchange rate on cash  
Cash – beginning of the year 
Cash  – end of the year 

 (24,257)     

 (21,660)     

 161,767  

 17     
 114    
 (16)    
 —    
 (84)    
 17,360    
 (18)     
 3,427     
 90    

 91  
 21     
 —  
 —    
 (7)  
 (15)    
 —    
 18  
 —      (175,770)  
 2,855  
 27  
 3,564  
 —  

 13,082    
 10     
 3,472     
 —    

 2     
 (64)     
 (506)     
 (3,935)     

 110     
 (101)     
 (36)     
 (5,117)     

 135  
 535  
 (1,466)  
 (8,251)  

 54    
 54     

 416    
 416     

 217  
 217  

 —     
 142     
 142     
 (3,739)     
 4     
 6,308     
 2,573     

 (119)     
 —     
 (119)     
 (4,820)     
 3     
 11,125     
 6,308     

 —  
 —  
 —  
 (8,034)  
 (15)  
 19,174  
 11,125  

(See accompanying notes to the consolidated financial statements) 

110 

 
 
 
 
 
 
 
 
 
 
 
 
 
  
    
    
  
 
  
 
  
 
          
  
     
       
    
  
  
     
     
  
  
  
  
  
  
  
  
  
  
  
     
     
  
  
  
  
  
  
       
       
    
  
  
  
       
       
    
  
  
  
  
  
  
  
 
 
Trilogy Metals Inc. 
Notes to Consolidated Financial Statements 

1)    Nature of operations and Going Concern 

Trilogy  Metals Inc.  (“Trilogy”,  the  “Company”,  or  “we”)  was  incorporated  in  British  Columbia  under  the  Business 
Corporations  Act  (BC)  on  April 27,  2011.  The  Company  is  engaged  in  the  exploration  and  development  of  mineral 
properties, through our equity investee (note 4), with a focus on the Upper Kobuk Mineral Projects (“UKMP”), including 
the Arctic and Bornite Projects located in Northwest Alaska in the United States of America (“US” or “USA”). The Company 
also conducts early-stage exploration through a wholly owned subsidiary, 995 Exploration Inc. 

These consolidated financial statements have been prepared on a going concern basis which assumes that the Company 
will be able to realize its assets and discharge its liabilities in the normal course of business for the foreseeable future.  
As  at  November  30,  2022,  the  Company  had  a  working  capital  surplus  of  $2.4  million  (2021  -  $5.6  million)  and  an 
accumulated deficit of $66.9 million (2021 - $42.6 million).  The Company has no recurring source of cash inflows at its 
current stage.  The Company’s cash outflow from operations was $3.9 million for the year ended November 30, 2022. 
The Company intends to finance its future requirements through a combination of debt and/or equity issuance.  There 
is no assurance that the Company will be able to obtain such financings or obtain them on a favourable terms.  These 
uncertainties raise substantial doubt about the Company’s ability to continue as a going concern.  These consolidated 
financial statements do not include any adjustments to the amounts and classification of assets and liabilities that might 
be necessary should the Company be unable to continue as a going concern. Such adjustments could be material. 

2)    Summary of significant accounting policies 

Basis of presentation 

These  consolidated  financial  statements  have  been  prepared  using  accounting  principles  generally  accepted  in  the 
United States (“U.S. GAAP”) and include the accounts of Trilogy and its wholly owned subsidiaries, NovaCopper US Inc. 
(dba “Trilogy Metals US”) and 995 Exploration Inc. All intercompany transactions are eliminated on consolidation. For 
variable interest entities (“VIEs”) where Trilogy is not the primary beneficiary, we use the equity method of accounting. 

All figures are in United States dollars unless otherwise noted. References to CDN$ refer to amounts in Canadian dollars. 

These financial statements were approved by the Company’s Board of Directors for issue on February 13, 2023. 

Cash  

Cash consists of cash held in banking institutions.  

Investment in affiliates 

Investments in unconsolidated ventures over which the Company has the ability to exercise significant influence, but 
does  not  control,  are  accounted  for  under  the  equity  method  and  include  the  Company’s  investment  in  the  Ambler 
Metals project. We identified Ambler Metals LLC (“Ambler Metals”) as a VIE as the entity is dependent on funding from 
its owners. All funding, ownership, voting rights and power to exercise control is shared equally on a 50/50 basis between 
the owners of the VIE. Therefore, the Company has determined that it is not the primary beneficiary of the VIE. The 
Company’s maximum exposure to loss is its investment in Ambler Metals. 

Management  assesses the possibility of impairment  in the carrying value of its equity method investment  in Ambler 
Metals whenever events or circumstances indicate that the carrying amount of the investment may not be recoverable. 
Significant  judgments  are  made  in  assessing  the  possibility  of  impairment.  Factors  that  may  be  indicative  of  an 

111 

 
 
 
Trilogy Metals Inc. 
Notes to Consolidated Financial Statements 

impairment include a loss in the value of an investment that is not temporary. Management considers several factors in 
considering if an indicator of impairment has occurred, including but not limited to, sustained losses by the investment, 
the absence of the ability to recover the carrying amount of the investment, deterioration of market conditions inclusive 
of  significant  changes  in  the  legal,  business  or  regulatory  environment,  significant  adverse  changes  impacting  the 
investee  and  internal  reporting  indicating  the  economic  performance  of  an  investment  is,  or  will  be,  worse  than 
expected. 

These factors are subjective and require consideration at each period end. If an indicator of impairment is determined 
to exist, the fair value of the impaired investment is determined based on the valuation of cohort companies with similar 
projects or upon the present value of expected future cash flows using discount rates and other assumptions believed 
to be consistent with those used by principal market participants and observed market earnings multiples of comparable 
companies. 

Management  calculates the  estimated undiscounted future net  cash flows relating to  the asset  or asset  group using 
estimated  future  prices,  proven  and  probable  reserves  and  other  mineral  resources,  and  operating,  capital  and 
reclamation costs. When the carrying value of an asset exceeds the related undiscounted cash flows, the asset is written 
down  to  its  estimated  fair  value,  which  is  usually  determined  using  discounted  future  cash  flows.  Management’s 
estimates  of  mineral  prices,  mineral  resources,  foreign  exchange  rates,  production  levels  operating,  capital  and 
reclamation costs are subject to risk and uncertainties that may affect the determination of the recoverability of the 
long-lived asset. It is possible that material changes could occur that may adversely affect management’s estimates. 

Fixed assets 

Plant and equipment are recorded at cost and amortization begins when the asset is put into service. Amortization is 
calculated on a straight-line basis over the respective assets’ estimated useful lives. Amortization periods by asset class 
are: 

Computer hardware and software 
Leasehold improvements 
Office furniture and equipment 

3 years 
lease term 
5 years 

Mineral properties and development costs 

All  direct  costs  related  to  the  acquisition  of  mineral  property  interests  are  capitalized.  Mineral  property  exploration 
expenditures  are  expensed  when  incurred.  When  it  has  been  established  that  a  mineral  deposit  is  commercially 
mineable,  an  economic  analysis  has  been  completed  and  permits  are  obtained,  the  costs  subsequently  incurred  to 
develop a mine on the property prior to the start of mining operations are capitalized. Capitalized costs will be amortized 
following  commencement  of  production  using  the  unit  of production  method  over  the  estimated  life  of  proven  and 
probable reserves. 

The acquisition of title to mineral properties is a complicated and uncertain process. The Company has taken steps, in 
accordance with industry standards, to verify the title to mineral properties. Although the Company has made efforts to 
ensure that legal titles to its mining assets are properly recorded through the 50/50 joint venture (the “Joint Venture”) 
named  Ambler  Metals  with  South32  Limited  (“South32”),  there  can  be  no  assurance  that  such  title  will  be  secured 
indefinitely. 

Impairment of long-lived assets 

Management  assesses  the  possibility  of  impairment  in  the  carrying  value  of  long-lived  assets  whenever  events  or 
circumstances  indicate  that  the  carrying  amounts  of  the  asset  or  asset  group  may  not be  recoverable.  Management 

112 

 
 
 
 
 
 
 
Trilogy Metals Inc. 
Notes to Consolidated Financial Statements 

calculates the estimated undiscounted future net cash flows relating to the asset or asset group using estimated future 
prices, proven and probable reserves and other mineral resources, and operating, capital and reclamation costs. When 
the carrying value of an asset exceeds the related undiscounted cash flows, the asset is written down to its estimated 
fair value, which is usually determined using discounted future cash flows. Management’s estimates of mineral prices, 
mineral resources, foreign exchange rates, production levels operating, capital and reclamation costs are subject to risk 
and  uncertainties  that  may  affect  the  determination  of  the  recoverability  of  the  long-lived  asset.  It  is  possible  that 
material changes could occur that may adversely affect management’s estimates. 

Leases 

At the inception of an arrangement, the Company determines whether the arrangement is or contains a lease based on 
the unique facts and circumstances present in the arrangement. Leases with a term greater than one year are recognized 
on the balance sheet as ROU assets and short-term and long-term lease liabilities, as applicable. ROU assets represent 
the Company’s right to use an underlying asset for the lease term and lease liabilities represent its obligation to make 
lease payments arising from the lease. The Company typically only includes an initial lease term in its assessment of a 
lease arrangement. It also considers termination options and factors those into the determination of lease payments. 
Options to renew a lease are not included in the assessment unless there is reasonable certainty that the Company will 
renew.  

Operating lease liabilities and their corresponding ROU assets are recorded based on the present value of lease payments 
over  the  expected  remaining  lease  term.  Certain  adjustments  to  the  ROU  asset  may  be  required  for  items  such  as 
incentives received.  The interest  rate implicit in lease contracts is typically not  readily  determinable. As a  result, the 
Company utilizes its incremental borrowing rate, which reflects the fixed rate at which it could borrow on a collateralized 
basis the amount of the lease payments in the same currency, for a similar term, in a similar economic environment. 
Lease expense for lease payments is recognized on a straight-line basis over the lease term. 

Income taxes 

The liability method of accounting for income taxes is used and is based on differences between the accounting and tax 
basis of assets and liabilities. Deferred income tax assets and liabilities are recognized for temporary differences between 
the tax and accounting basis of assets and liabilities as well as for the benefit of losses available to be carried forward to 
future years  for  tax  purposes  using  enacted  income  tax  rates  expected  to  be  in  effect  for  the  period  in  which  the 
differences are expected to reverse. Deferred income tax assets are evaluated and, if realization is not considered more 
likely than not, a valuation allowance is provided. 

Uncertainty in income tax positions 

The Company recognizes tax benefits from uncertain tax positions only if it is at least more likely than not that the tax 
position will be sustained on examination by the taxing authorities, based on the technical merits of the position. Any 
tax benefits recognized in the financial statements from such a position are measured based on the largest benefit that 
has a greater than 50% likelihood of being realized upon settlement with the taxing authorities. Related interest and 
penalties, if any, are recorded as tax expense in the tax provision. 

Financial instruments 

Valuation models require the use of assumptions which may include the expected life of the instrument, the expected 
volatility, dividend payouts, and interest rates. In determining these assumptions, management uses readily observable 
market inputs where available or, where not available, inputs generated by management. 

113 

 
Trilogy Metals Inc. 
Notes to Consolidated Financial Statements 

Loans and receivables are recorded initially at fair value, net of transaction costs incurred, and subsequently at amortized 
cost using the effective interest rate method. Loans and receivables consist of cash, accounts receivable, and deposits. 

Other financial liabilities are recorded initially at fair value and subsequently at amortized cost using the effective interest 
rate method. Other financial liabilities include accounts payable and accrued liabilities. 

Translation of foreign currencies 

Monetary assets and liabilities are translated into United States dollars at the exchange rate in effect at the balance sheet 
date, and non-monetary assets and liabilities at the exchange rate in effect at the time of acquisition or issue. Income 
and expenses are translated at rates approximating the exchange rate in effect at the time of transactions. Exchange 
gains or losses arising on translation are included in income or loss for the period. 

The functional currency of the Company and its subsidiary and the Company’s reporting currency is the United States 
dollar. 

Earnings and loss per share 

Earnings and loss per common share is calculated based on the weighted average number of common shares outstanding 
during the year. The Company follows the treasury stock method in the calculation of diluted earnings per share. Under 
the treasury stock method, the weighted average number of common shares outstanding used for the calculation of 
diluted loss per share assumes that the proceeds to be received on the exercise of dilutive stock options and in the prior 
year, warrants are used to repurchase common shares at the average market price during the period. 

Stock-based compensation 

Compensation expense for options granted to employees, directors and certain service providers is determined based 
on estimated fair values of the options at the time of grant using the Black-Scholes option pricing model, which takes 
into account, as of the grant date, the fair market value of the shares, expected volatility, expected dividend yield, the 
risk-free  interest  rate,  and  the  expected  life  of  the  option.  The  compensation  cost  is  recognized  using  the  graded 
attribution method over the vesting period of the respective options. The expense relating to the fair  value of stock 
options is included in expenses, net of forfeitures and is credited to contributed surplus. Shares are issued from treasury 
in settlement of options exercised. 

Compensation expense for restricted share units (“RSUs”) and deferred share units (“DSUs”) granted to employees and 
directors, respectively, is determined based on estimated fair values of the units at the time of grant using quoted market 
prices or at the time the units qualify for equity classification under ASC 718. The cost is recognized using the graded 
attribution method over the vesting period of the respective units. The expense relating to the fair value of the units is 
included  in expenses, net  of  forfeitures and is credited  to other liabilities or contributed surplus based on the unit’s 
classification. Units may be settled in either i) cash, and/or ii) shares purchased in the open market, and/or iii) shares 
issued from treasury, at the Company’s election at the time of vesting. 

Use of estimates and measurement uncertainties 

The  preparation  of  financial  statements  in  conformity  with  U.S. GAAP  requires  management  to  make  estimates  and 
assumptions  of  future  events  that  affect  the  reported  amount  of  assets  and  liabilities  and  disclosure  of  contingent 
liabilities at the date of the financial statements, and the reported amounts of expenditures during the period. Significant 
judgments  include  the  assessment  of  potential  indicators  of  impairment  of  mineral  properties  and  investments  in 
affiliates where key judgement is the delay on the Ambler Access Project is temporary and the delay was considered 
when  assessing  indicators  of  impairment.  Significant  estimates  include  the  measurement  of  the  South32  property 

114 

Trilogy Metals Inc. 
Notes to Consolidated Financial Statements 

acquisition  option  and  subsequent  equity  method  investment,  income  taxes,  and  the  valuation  of  stock-based 
compensation. Actual results could differ materially from those reported. 

3)    Accounts receivable 

GST input tax credits 
Accounts receivable 

4)    Investment in Ambler Metals LLC 

(a)  Formation of Ambler Metals LLC  

     November 30, 2022 

in thousands of dollars 
     November 30, 2021  

$           

 17  
 17  

$      

 19  
 19  

On February 11, 2020, the Company completed the formation of the 50/50 Joint Venture named Ambler Metals with 
South32.  As  part  of  the  formation  of  the  Joint  Venture,  Trilogy  contributed  all  its  assets  associated  with  the  UKMP, 
including the Arctic and Bornite Projects, while South32 contributed $145 million, resulting in each party’s subsidiaries 
directly owning a 50% interest in Ambler Metals. To assist Ambler Metals during the initial set up phase, Trilogy paid all 
of  Ambler  Metals’  invoices  and  was  being  reimbursed  pursuant  to  a  services  agreement  (the  “Services  Agreement”) 
between Trilogy and Ambler Metals until the back office transitioned to a new permanent team employed by the Joint 
Venture. The Services Agreement ended on December 31, 2020. 

Ambler Metals is an independently operated company jointly controlled by Trilogy and South32 through a four-member 
board, of which two members are currently appointed by Trilogy based on its 50% equity interest. All significant decisions 
related to the UKMP require the approval of both companies. We determined that Ambler Metals is a VIE because it is 
expected to need additional funding from its owners for its significant activities. However, we concluded that we are not 
the primary beneficiary of Ambler Metals as the power to direct its activities, through its board, is shared under the 
Ambler Metals LLC limited liability company agreement. As we have significant influence over Ambler Metals through 
our representation on its board, we use the  equity method of accounting for our investment  in Ambler Metals. Our 
investment in Ambler Metals was initially measured at its fair value of $176 million upon recognition. Our maximum 
exposure to loss in this entity is limited to the carrying amount of our investment in Ambler Metals, which totaled $142.8 
million  at  November  30,  2022.  The  following  table  summarizes  the  gain  on  derecognition  of  the  UKMP  assets  upon 
transfer to the Ambler Metals Joint Venture on February 11, 2020. 

Fair value ascribed to Ambler Metals LLC interest 
Less: carrying value of contributed /eliminated assets 
Mineral properties 
Property, plant and equipment located in Alaska 
Elimination of Fairbanks warehouse right of use asset 
Elimination of prepaid State of Alaska mining claim fees 
Add:  
Reimbursement of claims staking 
Demobilization costs of drills 
Cancellation of Fairbanks warehouse lease liability 
Fair value of mineral properties purchase option 
Gain on derecognition  

115 

     in thousands of dollars 
$      

 176,000  

 (30,631)  
 (618)  
 (93)  
 (303)  

 44  
 278  
 93  
 31,000  
 175,770  

 
 
 
 
 
 
 
 
     
 
 
 
     
 
  
 
  
 
 
 
 
 
 
 
 
 
 
     
 
 
    
 
 
 
 
 
    
 
 
 
 
 
Trilogy Metals Inc. 
Notes to Consolidated Financial Statements 

(b)  Carrying value of investment in Ambler Metals  

During the year ended November 30, 2022, Trilogy recognized, based on its 50% ownership interest in Ambler Metals, 
an equity loss equivalent to its pro rata share of Ambler Metals' net loss of $34.7 million for the year ended November 
30, 2022 ( 2021 - $26.2 million). The carrying value of Trilogy’s 50% investment in Ambler Metals as at November 30, 
2022 is summarized on the following table. 

   February 11, 2020, fair value ascribed to Ambler Metals interest 

Share of loss on equity investment from February 11, 2020 to November 30, 2020 
November 30, 2020, investment in Ambler Metals  
Share of loss on equity investment for the year ending November 30, 2021 
November 30, 2021, Investment in Ambler Metals  
Joint venture equity contribution 
Share of loss on equity investment for the year ending November 30, 2022 
November 30, 2022, Investment in Ambler Metals  

(c)  The following table summarizes Ambler Metals’ Balance Sheet as at November 30, 2022. 

     in thousands of dollars 
$      

 176,000 
 (2,855) 
 173,145  
 (13,082)  
 160,063  
 51  
 (17,360)  
 142,754  

Total assets 
   Cash 
   Loan receivable from South32 (current and long-term) 
   Mineral properties 
Total liabilities 
   Accounts payable and accrued liabilities 
Members' equity (total assets less total liabilities) 

  November 30, 2022 

in thousands of dollars 
  November 30, 2021 

$           

$      

 114,049  
 80,755  
 —  
 30,899  
 (4,335)  
 (3,664)  
 109,714  

 149,374  
 61,205  
 55,355  
 30,757  
 (5,043)  
 (4,148)  
 144,331  

(d)  The following table summarizes Ambler Metals’ net loss for the years ended November 30, 2022 and November 30, 

2021. 

Depreciation 
Corporate salaries and wages 
General and administrative  
Mineral property expense 
Professional fees 
Foreign exchange (gain)/loss 
Interest income 
Comprehensive loss 

in thousands of dollars 

Year ended 

  November 30, 2022 

 November 30, 2021 

$           

$      

113 
1,664 
738 
32,083 
792 
 15 
 (686) 
 34,719 

 77  
 2,381  
 991  
 22,720  
 1,047  
 6  
 (1,058)  
 26,164  

116 

 
 
 
 
 
 
 
     
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
     
 
 
 
 
     
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
     
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
5)    Fixed assets 

Cost 
November 30, 2020 
ROU asset reclass 
November 30, 2021 
Write off fully depreciated 
assets 
November 30, 2022 

Accumulated amortization 
November 30, 2020 
ROU asset reclass 
Depreciation 
November 30, 2021 
Depreciation 
Write off fully depreciated 
assets 
November 30, 2022 

Net Book Value 
November 30, 2021 
November 30, 2022 

Trilogy Metals Inc. 
Notes to Consolidated Financial Statements 

(e)  Related party transactions  

During the fiscal year 2022, the Company transferred a mineral claim to Ambler Metals and received net proceeds 
of approximately $140,000. 

During  the  fiscal  year  2021,  the  Company  charged  $22,000  of  expenses  related  to  technical  services,  including 
geological,  engineering,  environmental  and  human  resources  and  accounting  services  in  connection  with  the 
Services Agreement. In addition, the Company received payments $4,000 related to operating expenses  paid on 
behalf of Ambler Metals. 

British Columbia, Canada 

Furniture and 

equipment         

Leasehold 
improvements         

Computer 
hardware and 

software         

in thousands of dollars   

$  
 63   
 —   
 63   

 (63)  
 —   

 42   
 —   
 14   
 56   
 7   

 (63)  
 —   

 7   
 —   

$  
 253   
 (200)  
 53   

 —   
 53   

 69   
 (44)  
 6   
 31   
 10   

 —   
 41   

 22   
 12   

                  Total    
$  
 431   
 (200)  
 231   

 (178)  
 53   

 225   
 (44)  
 21   
 202   
 17   

 (178)  
 41   

 29   
 12   

$  
 115   
 —   
 115   

 (115)  
 —   

 114   
 —   
 1   
 115   
 —   

 (115)  
 —   

 —   
 —   

Write off 

in thousands of dollars   
November 30, 2022   
$    

$       

 — 
 (61)    
 (61)     

 —  
 —  
 —  

6)    Mineral properties and development costs 

Alaska, USA 
West Kobuk 
East Ambler 

  November 30, 2021 

$       

 58 
 61 
 119 

Disposal   
$  

 (58)  
 —   
 (58)  

117 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
     
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
  
 
  
 
  
 
  
 
  
 
  
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
  
 
  
 
  
 
  
 
  
 
  
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
  
 
  
 
  
 
     
 
 
        
 
 
      
    
 
  
 
  
 
  
 
 
 
   
 
 
Trilogy Metals Inc. 
Notes to Consolidated Financial Statements 

(a)  Mineral properties expense 

The  following  table  summarizes  mineral  properties  expense  for  the UKMP,  Alaska,  USA  for  the  years  ended 
November 30, 2022, 2021 and 2020, and includes expenditures funded by South32 up to the formation of the Joint 
Venture on February 11, 2020, as applicable. 

Alaska, USA 
Community 
Engineering 
Environmental 
Geochemistry and geophysics 
Land and permitting 
Project support 
Wages and benefits 

In thousands of dollars 

2022  

$        

2021  

$        

2020 

$    

 —   
 —   
 —   
 —   
 —   
 —   
 —   
 —   

 —   
 —   
 —   
 —   
 —   
 —   
 —   
 —   

 137  
 723  
 99  
 12  
 134  
 249  
 191  
 1,545  

Mineral property expenses consisted of direct drilling, personnel, community, resource reporting and other exploration 
expenses as outlined above, as well as indirect project support expenses such as fixed wing charters, helicopter support, 
fuel, and other camp operation costs. Other than the feasibility costs related to the Arctic project funded directly by the 
Company, no additional mineral properties expenses were incurred subsequent to the formation of the Joint Venture, 
as on February 11, 2020, upon the formation of the Joint Venture with South32, all mineral properties previously held 
by the Company were contributed to Ambler Metals.  

The Company funded the Arctic Project feasibility study costs of $1.1 million since the formation of the Joint Venture on 
February 11, 2020. Prior to the formation of the Joint Venture, the Company had also incurred $0.7 million in Arctic 
Project feasibility costs that are included in the mineral properties expense balance of  $1.5 million for the year ended 
November 30, 2020. 

Cumulative  mineral  properties  expense  in  Alaska  from  the  initial  earn‐in  agreement  on  the  property  in  2004  to  the 
formation of the Joint Venture on February 11, 2020 was $115.3 million and cumulative acquisition costs were $30.6 
million. Cumulative spend to date totaled $147 million. On February 11, 2020, upon the formation of the Joint Venture 
with South32, the acquisition costs of $30.6 million were derecognized upon the contribution of the mineral properties 
to Ambler Metals. 

(b)  Derecognition 

As  part  of  the  formation  of  the  Joint  Venture  with  South32  on  February  11,  2020,  Trilogy  contributed  all  its  assets 
associated  with  the  UKMP,  including  the  Arctic  and  Bornite  projects.  As  a  result,  machinery  and  equipment  with  a 
carrying value of $0.62 million as well as $30.6 million of mineral properties related to the UKMP were derecognized by 
Trilogy on February 11, 2020. 

118 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
  
 
   
 
 
 
  
 
 
 
 
 
 
 
 
         
   
     
 
     
 
    
   
 
 
   
 
 
   
 
 
   
 
 
   
 
 
   
 
 
   
 
 
 
   
 
 
 
 
 
 
 
Trilogy Metals Inc. 
Notes to Consolidated Financial Statements 

7)    Accounts payable and accrued liabilities 

Trade accounts payable 
Accrued liabilities 
Accrued salaries and vacation 
Accounts payable and accrued liabilities 

8)    Leases 

(a)  Right-of-use asset 

Balance as at November 30, 2020 
Net amortization 
Previously classified in fixed assets 
Balance as at November 30, 2021 
Net amortization 
Balance as at November 30, 2022 

(b)  Lease liabilities 

  November 30, 2022  

  November 30, 2021 

in thousands of dollars   

$           

 188  
 36   
 121   
 345   

$      

 205 
 105  
 542  
 852  

  in thousands of dollars 
$      

 476  
 (150)  
 156  
 482  
 (163)  
 319  

The Company’s lease arrangements primarily consist of an operating lease for our office space ending in June 2024. There 
are no extension options. 

Total lease expense recorded within general and administrative expenses was comprised of the following components: 

Operating lease costs 
Variable lease costs 
Total lease expense 

Year ended    

in thousands of dollars 
Year ended    

  November 30, 2022 

  November 30, 2021 

$           

 187  
 143  
 330  

$      

 187  
 122  
 309  

Variable lease costs consist primarily of the Company’s portion of operating costs associated with the office space lease 
as the Company elected to apply the practical expedient not to separate lease and non-lease components.  

As of November 30, 2022, the remaining lease term was 1.5 years and the discount rate is 8%. Significant judgment was 
used in the determination of the incremental borrowing rate which included estimating the Company’s credit rating. 

Supplemental cash and non-cash information relating to our leases during the year ended November 30, 2022 are as 
follows: 

• 

Cash paid for amounts included in the measurement of lease liabilities was $203,001. 

119 

 
 
 
 
 
 
 
 
 
  
 
 
 
 
     
 
 
 
  
 
  
 
  
 
 
 
 
 
 
 
 
 
     
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
     
 
 
 
 
 
 
 
     
 
 
 
 
 
 
 
Trilogy Metals Inc. 
Notes to Consolidated Financial Statements 

Future minimum payments relating to the lease recognized in our balance sheet as of November 30, 2022 are as follows: 

Fiscal year 
2023 
2024 
2025 
Total undiscounted lease payments 
Effect of discounting 
Present value of lease payments recognized as lease liability 

9)    Share capital 

Authorized: 

unlimited common shares, no par value 

November 30, 2020 
Exercise of options 
November 30, 2021 
Exercise of options 
Restricted Share Units 
Services settled by common shares 
Joint venture equity contribution (note 4(b)) 
November 30, 2022, issued and outstanding  

     in thousands of dollars 
  November 30, 2022    
$      

 199  
 33  
 —  
 232  
 (10)  
 222  

in thousands of dollars, except share amounts 
Ascribed value 

  Number of shares 

 144,137,850 
 871,961 
 145,009,811 
 81,674 
 992,081 
 110,000 
 31,469 
 146,225,035 

$      

 179,746  
 1,074  
 180,820  
 76  
 1,117  
 114  
 51  
 182,178  

On April 30, 2012, under the NovaGold Arrangement, Trilogy committed to issue common shares to satisfy holders of 
NovaGold deferred share units (“NovaGold DSUs”), once vested, on record as of the close of business April 27, 2012. 
When vested, Trilogy committed to deliver one common share to the holder for every six shares of NovaGold the holder 
is entitled to receive, rounded down to the nearest whole number. As of November 30, 2022, a total of 11,927 NovaGold 
DSUs remain outstanding representing a right to receive 1,988 Common Shares in Trilogy, which will settle upon certain 
directors retiring from NovaGold’s board. 

(a)  Stock options 

The Company has a stock option plan providing for the issuance of options with a rolling maximum number equal to 10% 
of  the  issued  and  outstanding  Common  Shares  at  any  given  time.  The  Company  may  grant  options  to  its  directors, 
officers, employees and service providers. The exercise price of each option cannot be lower than the greater of market 
price or fair market value of the Common Shares (as such terms are defined in the plan) at the date of the option grant. 
The number of Common Shares optioned to any single optionee may not exceed  10% of the issued and outstanding 
Common Shares at the date of grant. The options are exercisable for a maximum of five years from the date of grant and 
may be subject to vesting provisions. 

120 

 
 
 
 
 
 
 
     
  
  
  
  
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
     
 
          
  
  
  
  
  
  
 
  
 
  
 
  
 
  
 
  
 
Trilogy Metals Inc. 
Notes to Consolidated Financial Statements 

During  the year  ended  November 30,  2022,  the  Company  granted  1,734,500  stock  options  (2021  –  3,374,150  stock 
options,  2020  –  4,445,000)  at  an  exercise  price  of  CDN$2.21  (2021 -  CDN$2.52,  2020  –  CDN$2.79)  to  employees, 
consultants and directors exercisable for a period of  five years with various vesting terms from immediate vesting to 
over a two-year period. The fair value attributable to options granted in 2022 was $0.71 (2021 -$0.84, 2020 - $0.90). 

The fair value of the stock options recognized for the year ended November 30, 2022 has been estimated using the Black-
Scholes option pricing model. 

Assumptions used in the pricing model for the year are as provided below. 

Risk-free interest rates 
Exercise price 
Expected life 
Expected volatility 
Expected dividends 

     November 30, 2022 
1.07% 
CDN$2.28 
3 years 
60.6% 
Nil 

The Company recognized  a  stock option expense of  $1.4 million for the year ended November 30, 2022 (2021  - $3.3 
million; 2020 - $3.1 million), net of forfeitures. 

As of November 30, 2022, there were 1,379,836 non-vested options outstanding with a weighted average exercise price 
of CDN$2.35. The non-vested stock option expense not yet recognized was $0.1 million. This expense is expected to be 
recognized over the next twelve months.  

A summary of the Company’s stock option plan and changes during the year ended is as follows: 

Balance – beginning of the year 
Granted 
Exercised 
Cancelled 
Forfeited 
Balance – end of the year 

 November 30, 2022 
    Weighted average 
exercise price 

     Number of options           

 10,539,324 
 1,734,500 
 (81,674) 
 (678,750) 
 (288,000) 
 11,225,400 

CDN$      
 2.54  
 2.21  
 0.85  
 3.80  
 2.35  
 2.49  

121 

 
 
 
 
 
  
  
  
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
  
  
  
  
  
  
  
  
 
  
  
  
 
Trilogy Metals Inc. 
Notes to Consolidated Financial Statements 

During the year ended November 30, 2022, the Company received net proceeds of $54,295 upon the exercise of 81,674 
options. 

The following table summarizes information about the stock options outstanding at November 30, 2022. 

Outstanding     
Weighted     

Exercisable      Unvested    

Weighted     

  Number of 
  outstanding 

Weighted 
   average years 

average      Number of     
 exercisable   

   exercise price   

 exercise price   

Range of exercise price - CDN 
$1.00 to $1.50 
$2.01 to $2.50 
$2.51 to $3.00 
$3.01 to $3.41 

options        
 870,000 
 2,396,250 
 6,411,650 
 1,547,500 
   11,225,400 

to expiry        
 0.02 
 3.29 
 2.47 
 2.06 
 2.40 

CDN$        
 1.05     
 2.27     
 2.64     
 3.03     
 2.49     

options        
 870,000     
 1,632,748     
 5,795,316     
 1,547,500     
 9,845,564     

average      Number of    
  unvested   
CDN$         options       
 —   
 1.05     
 763,502   
 2.29     
 616,334   
 2.65     
 —   
 3.03     
 1,379,836   
 2.51     

The aggregate intrinsic value of vested share options (the market value less the exercise price) at November 30, 2022 
was $nil (2021 - $0.8 million, 2020 - $2.4 million) and the aggregate intrinsic value of exercised options for the year ended 
November 30, 2022 was $0.04 million (2021 - $1.4 million, 2020 - $2.6 million). 

(b)  Restricted Share Units and Deferred Share Units 

The Company has a Restricted Share Unit Plan (“RSU Plan”) and a Non-Executive Director Deferred Share Unit Plan (“DSU 
Plan”) to provide long-term incentives to employees, officers and directors. The RSU Plan and DSU Plan may be settled 
in cash and/or common shares at the Company’s election with each RSU and DSU entitling the holder to receive  one 
common share of the Company or equivalent value. All units are accounted for as equity-settled awards. 

There were 1,359,349 RSUs granted during the fiscal year ended November 30, 2022 (2021 – nil, 2019 – nil). Directors 
were granted 283,289 DSUs throughout the year ended November 30, 2022 (2021 – 58,925, 2020 – 83,775) based on 
their election to receive 50% of their annual retainer in DSUs. 

A summary of the Company’s RSU and DSU Plan and changes during the year ended November 30, 2022 is as follows: 

Balance – beginning of the year 
Granted 
Vested 
Balance – end of the year 

     Number of RSUs           Number of DSUs      

 — 
 1,359,349 
 (1,102,081) 
 257,268 

 1,277,445  
 283,289  
 —  
 1,560,734  

For the year ended November 30, 2022, Trilogy recognized a stock-based compensation expense of $2.0 million (2021 - 
$0.1 million, 2020 - $0.5million). 

10)    Management of capital risk 

The  Company  relies  upon  management  to  manage  capital  in  order  to  accomplish  the  objectives  of  safeguarding  the 
Company’s ability to continue as a going concern in order to pursue the development of the mineral properties, at the 
UKMP, through our equity investee (note 4) and maintain a capital structure which optimizes the costs of capital at an 
acceptable risk. The Company’s current capital consists of equity funding through capital markets. 

122 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
    
 
   
   
 
  
  
 
   
  
   
  
  
   
  
 
  
  
 
  
  
 
  
  
 
 
 
 
 
 
 
 
 
 
   
  
   
  
   
  
   
 
 
Trilogy Metals Inc. 
Notes to Consolidated Financial Statements 

As the Company is currently in the exploration phase none of its financial instruments are exposed to commodity price 
risk;  however,  the  Company’s  ability  to  obtain  long-term  financing  and  its  economic  viability  may  be  affected  by 
commodity price volatility. The Company will need to raise additional funds to support its operations and administration 
expenses. Future sources of liquidity may include equity financing, debt financing, convertible debt, or other means. 

To facilitate the management of its capital requirements, the Company prepares annual expenditure budgets that are 
updated  as  necessary  depending  on  various  factors,  including  successful  capital  deployment  and  general  industry 
conditions. 

11)   Financial instruments 

The Company is exposed to a variety of risks arising from financial instruments. These risks and management’s objectives, 
policies and procedures for managing these risks are disclosed as follows. 

The Company’s financial instruments consist of cash, accounts receivable, deposits, and accounts payable and accrued 
liabilities. The fair value of the Company’s financial instruments approximates their carrying value due to the short-term 
nature of their maturity. The Company’s financial instruments initially measured at fair value and then held at amortized 
cost include cash, accounts receivable, deposits, and accounts payable and accrued liabilities.  

Financial risk management 

The Company’s activities expose them to certain financial risks, including currency risk, credit risk, liquidity risk, interest 
risk and price risk. 

(a)  Currency risk 

Currency risk is the risk of a fluctuation in financial asset and liability settlement amounts due to a change in foreign 
exchange rates. The Company operates in the United States and Canada. The Company’s exposure to currency risk at 
November 30, 2022 is limited to the Canadian dollar balances consisting of cash of CDN$223,000, accounts receivable of 
CDN$22,000 and certain trade payables and accrued personnel costs CDN$393,000. Based on a 10% change in the US-
Canadian  exchange  rate,  assuming  all  other  variables  remain  constant,  the  Company’s  net  loss  would  change  by 
approximately $10,000. 

(b)  Credit risk 

Credit  risk  is  the  risk  of  an  unexpected  loss  if  a  customer  or  third  party  to  a  financial  instrument  fails  to  meet  its 
contractual obligations. The  Company holds cash with Canadian chartered financial  institutions. The Company’s only 
significant exposure to credit risk is equal to the balance of cash as recorded in the financial statements. 

(c)  Liquidity risk 

Liquidity risk is the risk that the Company will encounter difficulties raising funds to meet its financial obligations as they 
fall  due.  The  Company  is  in  the  exploration  stage  and  does  not  have  cash  inflows  from  operations;  therefore,  the 
Company manages liquidity risk through the management of its capital structure and financial leverage. 

123 

 
Trilogy Metals Inc. 
Notes to Consolidated Financial Statements 

Contractually obligated cash flow requirements as at November 30, 2022 are as follows. 

Accounts payable and accrued liabilities 
Office lease 

(d)  Interest rate risk 

in thousands of dollars     
Total        < 1 Year       1–2 Years       2–5 Years       Thereafter     
$  
 —  
 33  
 33  

$  
 345  
 199  
 544  

$  
 345  
 232  
 577  

$  
 —  
 —   
 —  

$  
 —  
 —  
 —  

Interest rate risk is the risk that the fair value or future cash flows of a financial instrument will fluctuate because of 
changes in market interest rates. The Company is exposed to interest rate risk with respect to interest earned on cash. 
Based on balances as at November 30, 2022 a 1% change in interest rates would result in a negligible change in net loss, 
assuming all other variables remain constant. 

As we are currently in the exploration phase none of our financial instruments are exposed to commodity price risk; 
however,  our  ability  to  obtain  long-term  financing  and  its  economic  viability  could  be  affected  by  commodity  price 
volatility. 

Fair value accounting 

Financial instruments measured at fair value are classified into one of three levels in the fair value hierarchy according 
to the significance of the inputs used in making the measurement. The three levels of the fair value hierarchy are as 
follows: 

Level 1 — Unadjusted quoted prices in active markets that are accessible at the measurement date for identical, 
unrestricted assets or liabilities; 

Level 2 — Quoted prices in markets that are not active, or inputs that are observable, either directly or indirectly, 
for substantially the full term of the asset or liability; and 

Level  3 —  Prices  or  valuation  techniques  that  require  inputs  that  are  both  significant  to  the  fair  value 
measurement and unobservable (supported by little or no market activity). 

The  Company  did  not  have  any  financial  assets  and  liabilities  that  were  measured  and recognized  at  fair  value  as  at 
November 30, 2022. 

124 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
  
  
  
 
 
  
 
 
 
 
 
  
  
  
 
 
 
 
Trilogy Metals Inc. 
Notes to Consolidated Financial Statements 

12)    Income taxes  

Income tax expense differs from the amount that would result from applying the Canadian federal and provincial income 
tax rates to earnings before income taxes. These differences result from the following items: 

  November 30, 2022  

  November 30, 2021  

in thousands of dollars 
  November 30, 2020  

$           

$           

$      

Combined federal and provincial 
statutory tax rate 
Income tax (recovery) at statutory rate   
Difference in foreign tax rates 
Effect of foreign exchange changes 
Non-deductible expenditures 
Income from option payments applied 
as proceeds of sale 
Change in estimates in respect of prior 
years 
Impact of new lease accounting rules 
(ASC 842 adoption) 
Change in valuation allowance 
Income tax recovery (expense) 

 27.00 %    
 (6,549)  
 (252)  
 —  
 374  

 —  

 39  

 —  
 6,388  
 —  

 27.00 %    
 (5,848)  
 (194)  
 —  
 937  

 —  

 116  

 —  
 4,989  
 —  

 27.00 % 

 43,677  
 2,424  
 (4)  
 1,009  

 (8,812)  

 (6)  

 (28)  
 (38,260)  
 —  

Deferred  income  taxes  arise  from  temporary  differences  in  the  recognition  of  income  and  expenses  for  financial 
reporting and tax purposes. The significant components of deferred income tax assets and  liabilities at November 30, 
2022 and 2021 are as follows: 

     in thousands of dollars    
  November 30, 2022     November 30, 2021    
$    
$       

Deferred income tax assets 

Non-capital losses 
Mineral property interest 
Mineral property impairment 
Deferred interest 
Property, plant and equipment 
Lease liability 
Share issuance costs 
Other deductible temporary differences 

Total deferred tax assets 
Valuation allowance 
Net deferred income tax assets 
Deferred income tax liabilities 

Investment in Ambler Metals LLC 
Right of use asset 

Deferred income tax liabilities 
Net deferred income tax assets 

125 

 57,236    
 3,061    
 17    
 6,251    
 86    
 60    
 6    
 181    
 66,898    
 (40,555)    
 26,343    

 (26,257)    
 (86)    
 (26,343)    
 —    

 54,502  
 447  
 —  
 6,251  
 82  
 112  
 103  
 197  
 61,694  
 (34,249)  
 27,445  

 (27,315)  
 (130)  
 (27,445)  
 —  

 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
  
 
 
 
 
     
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
     
 
      
    
 
 
 
 
 
 
 
 
 
 
 
 
      
    
 
 
 
 
 
Trilogy Metals Inc. 
Notes to Consolidated Financial Statements 

The Company has loss carry-forwards of approximately $203 million that may be available for tax purposes. Certain of 
these losses occurred prior to the incorporation of the Company and are accounted for in the financial statements as if 
they were incurred by the Company. Prior to the NovaGold Arrangement, the Company undertook a tax reorganization 
in order to preserve the future deductibility of these losses for the Company, subject to the limitations below. Deferred 
tax assets have been recognized to the extent of future taxable income and the future taxable amounts related to taxable 
temporary  differences  for  which  a  deferred  tax  liability  is  recognized  can  be  offset.  A  valuation  allowance  has  been 
provided against deferred income tax assets where it is not more likely than not that the Company will realize those 
benefits. 

The losses expire as follows in the following jurisdictions: 

  Non-capital losses 
Canada 

2023 
2024 
2025 
2026 
Thereafter 

 — 
 — 
 — 
 — 
 57,380 
 57,380 

$       

     in thousands of dollars   
Operating losses   
United States   
$    
 960  
 569  
 1,530  
 7,871  
 135,817  
 146,747  

Future use of U.S. loss carry-forwards is subject to certain limitations under provisions of the Internal Revenue Code 
including limitations subject to Section 382, which relates to a 50% change in control over a three-year period and are 
further dependent upon the Company attaining profitable operations. An ownership change under Section 382 occurred 
on January 22, 2009 regarding losses incurred by AGC, of which the attributes of those losses were transferred to Trilogy 
Metals US with the purchase of the mineral property in October 2011. Therefore, approximately $39.4 million of the U.S. 
losses above are subject to limitation under Section 382. Accordingly, the Company’s ability to use these losses may be 
limited.  An  additional  change  in  control  may  have  occurred  after  November 30,  2011  which  may  further  limit  the 
availability of losses prior to the date of change in control. 

Furthermore, tax reform provisions under Section 172 allow federal net operating losses arising in tax years subsequent 
to December 31, 2017 to be carried forward indefinitely. As at November 30, 2022 the Company has approximately $26 
million in operating losses that can be carried forward indefinitely. 

On  June 19,  2015,  we  completed  the  Sunward  acquisition  which  resulted  in  an  acquisition  of  control  of  Sunward 
Resources ULC under of the Income Tax Act in Canada. Therefore, the Company’s ability to use approximately $15.2 
million of losses in Canada may be limited. 

13)    Commitment 

The Company has commitments with respect to an office lease requiring future minimum lease payments as summarized 
in note 8(b). 

126 

 
 
 
 
 
 
 
 
 
 
 
  
 
 
  
 
     
 
  
 
  
 
  
 
  
 
  
 
 
  
 
 
 
 
 
 
Trilogy Metals Inc. 
Notes to Consolidated Financial Statements 

14)    Subsequent events 

On December 1, 2022, senior management and the Board of Directors were granted 392,497 RSUs and 60,519 DSUs in 
settlement of approximately $170,000 for salaries and $35,000 for director fees. 

On December 8, 2022, the Company granted 1,056,350 RSUs for short term incentives to executive and employees, all 
vesting  immediately.  Directors  were  granted  700,000  DSUs  and  580,000  stock  options,  all  vesting  immediately. 
Employees and consultants were granted 2,650,000 stock options and 2,250,000 RSUs with vesting schedule one-third 
vesting immediately, one-third to vest on the one year anniversary of the grant date and one-third to vest on the second 
year anniversary of the grand date. 

127 

 
 
 
Item 9.    CHANGES IN AND DISAGREEMENTS WITH ACCOUNTANTS ON 
ACCOUNTING AND FINANCIAL DISCLOSURE 

None. 

Item 9A.  CONTROLS AND PROCEDURES 

Disclosure Controls and Procedures 

Disclosure controls and procedures are designed to ensure that information required to be disclosed in reports filed or 
submitted  by  the  Company  under  U.S.  and  Canadian  securities  legislation  is  recorded,  processed,  summarized  and 
reported  within  the  time  periods  specified  in  those  rules,  including  providing  reasonable  assurance  that  material 
information is gathered and reported to senior management, including the Chief Executive Officer (“CEO”) and Chief 
Financial Officer (“CFO”), as appropriate, to permit timely decisions regarding public disclosure. Management, including 
the CEO and CFO, has evaluated the effectiveness of the design and operation of the Company’s disclosure controls and 
procedures,  as  defined  in  Rule 13a-15(e) and15d-15(e) of  the Exchange  Act  and  the  rules of  Canadian  Securities 
Administrators, as at November 30, 2022. Based on this evaluation, the CEO and CFO have concluded that the Company’s 
disclosure controls and procedures were effective as at November 30, 2022. 

Internal Control over Financial Reporting 

Management is responsible for establishing and maintaining adequate internal control over financial reporting as defined 
in Rule 13a-15(f) and 15d-15(f) of the Exchange Act and National Instrument 52-109 Certification of Disclosure in Issuer’s 
Annual and Interim filings. Any system of internal control over financial reporting, no matter how well designed, has 
inherent limitations. Therefore, even those systems determined to be effective can provide only reasonable assurance 
with respect to financial statement preparation and presentation. Management has used the Committee of Sponsoring 
Organizations  of  the  Treadway  Commission  in  Internal  Control  –  Integrated  Framework  (2013)  to  evaluate  the 
effectiveness of the Company’s internal control over financial reporting. Based on this assessment, management has 
concluded that as at November 30, 2022, the Company’s internal control over financial reporting was effective. 

Attestation Report of the Registered Public Accounting Firm 

This Annual Report does not include an attestation report of the company’s registered public accounting firm regarding 
internal controls over financial reporting.  Management’s report was not subject to attestation by our registered public 
accounting firm pursuant to law, rules and regulations that permit us to provide only management’s report in this Annual 
Report.   

Changes in Internal Controls 

There has been no change in our internal control over financial reporting during fiscal year ended November 30, 2022 
that has materially affected, or is reasonably likely to materially affect, our internal control over financial reporting. 

Item 9B.  OTHER INFORMATION 

None. 

Item 9C.  DISCLOSURE REGARDING FOREIGN JURISDICTIONS THAT PREVENT 
INSPECTIONS 

Not applicable. 

128 

 
 
 
PART III 

Item 10.  DIRECTORS, EXECUTIVE OFFICERS AND CORPORATE GOVERNANCE 

The  information  in  our  2023  Proxy  Statement  regarding  directors  and  executive  officers  and  Section 16  reporting 
information appearing under the headings “Election of Directors” and “Information Concerning the Board of Directors 
and  Executive  Officers”  is  incorporated  by  reference  in  this  section.  The  information  under  the  heading  “Executive 
Officers of Trilogy” in Part I, Item 1 of this Form 10-K is also incorporated by reference in this section. The information in 
our 2023 Proxy Statement regarding our Code of Business Conduct and Ethics under the subheading “Ethical Business 
Conduct” under “Statement of Corporate Governance Practices” is also incorporated by reference in this section. Finally, 
the information in our 2023 Proxy Statement regarding the Audit Committee under the heading “Statement of Corporate 
Governance Practices” is incorporated herein by reference. 

Item 11.  EXECUTIVE COMPENSATION 

The information appearing in our 2023 Proxy Statement under the headings “Compensation Committee Interlocks and 
Insider  Participation”,  “Statement  of  Executive  Compensation”,  and  “Director  Compensation”  is  incorporated  by 
reference in this section. 

Item 12.  SECURITY OWNERSHIP OF CERTAIN BENEFICIAL OWNERS AND 

MANAGEMENT AND RELATED STOCKHOLDER MATTERS 

The information appearing in our 2022 Proxy Statement under the heading “Securities Authorized For Issuance Under 
Equity  Compensation  Plans”  (which  is  also  contained  in  this  report  in  Part II, Item  5)  and  the  information  under  the 
heading  “Security  Ownership  Of  Certain  Beneficial  Owners  And  Management  And  Related  Shareholder  Matters”  is 
incorporated herein by reference. 

Securities Authorized for Issuance under Equity Compensation Plans 

The following table is as of November 30, 2022. 

Plan category 

Equity compensation plans 
approved by security holders 
Equity compensation plans not 
approved by security holders 

Total 

Number of securities to be issued 
upon exercise of outstanding 
options, warrants and rights       
(a)      

Weighted-
average exercise price of 
outstanding options, warrants and 

Number of securities remaining 
available for future issuance under 
equity compensation plans 
(excluding securities reflected in 

rights       
(b)    

 1.79    

 —    

 1.79    

column (a))    
(c)  

 8,890,354  

 —  
 8,890,354  

 13,043,402    

$ 

 —    

 13,043,402     $ 

129 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
      
 
   
   
   
 
   
 
 
Item 13.  CERTAIN RELATIONSHIPS AND RELATED TRANSACTIONS, AND DIRECTOR 

INDEPENDENCE 

The  information  appearing  in  our  2023  Proxy  Statement  under  the  heading  “Independence  of  Directors”  under  the 
heading “Information Concerning the Board of Directors and Executive Officers” and under the heading “Statement of 
Corporate Governance Practices” is incorporated herein by reference. 

Item 14.  PRINCIPAL ACCOUNTANT FEES AND SERVICES 

The information appearing in our 2023 Proxy Statement regarding Audit Fees, Audit-Related Fees, Tax Fees, All Other 
Fees and Audit Committee Pre-Approval Policies under the subheading “Appointment of Auditors” is incorporated herein 
by reference. 

Item 15.  EXHIBITS AND FINANCIAL STATEMENT SCHEDULES 

PART IV 

(a) 

Documents Filed With This Report 

1. 

FINANCIAL STATEMENTS 

Report of Independent Registered Public Accounting Firm (PCAOB ID 271) 

Consolidated Balance Sheets  

Consolidated Statements of Loss and Comprehensive Loss  

Consolidated Statements of Shareholders’ Equity 

Consolidated Statements of Cash Flows  

Notes to Consolidated Financial Statements  

Page 

105 

107 

108 

109 

110 

111 

2. 

FINANCIAL STATEMENT SCHEDULES 

None. 

3. 

EXECUTIVE COMPENSATION PLANS AND ARRANGEMENTS 

Employment Agreement between the Registrant and Tony Giardini, dated April 20, 2020, identified in exhibit 
list below. 

Employment  Agreement  between  the  Registrant  and  Elaine  Sanders,  dated  November  5,  2012,  identified  in 
exhibit list below. 

NovaCopper Inc. Equity Incentive Plan identified in exhibit list below. 

Form of NovaCopper Inc. Stock Option Agreement identified in exhibit list below. 

NovaCopper Inc. 2012 Restricted Share Unit Plan identified in exhibit list below. 

Form of NovaCopper Inc. 2012 Restricted Share Unit Award Agreement identified in exhibit list below. 

NovaCopper Inc. 2012 Deferred Share Unit Plan identified in exhibit list below. 

Form of NovaCopper Inc. Deferred Share Unit Award Agreement identified in exhibit list below. 

130 

 
 
 
 
 (b) 

Exhibits 

Exhibit 
No. 
2.1 

  Contribution  Agreement,  dated  February  11,  2020,  between  NovaCopper  US  Inc.,  Trilogy  Metals  Inc.  and 
Ambler Metals LLC (incorporated by reference to Exhibit 2.1 to the Company’s Current Report on Form 8-K 
filed on February 18, 2020) 

Description 

3.1 

  Certificate  of  Incorporation  (incorporated  by  reference  to  Exhibit  99.2  to  the  Company’s  Registration 

Statement on Form 40-F filed on March 1, 2012)  

3.2 

  Articles of Trilogy Metals Inc., effective April 27, 2011, as altered March 20, 2011 (incorporated by reference 
to Exhibit 99.3 to Amendment No. 1 to the Company’s Registration Statement on Form 40-F filed on April 19, 
2012) 

3.3 

  Notice of Articles and Certificate of Name Change, dated September 1, 2016 (incorporated by reference to 

Exhibit 3.1 to the Company’s Current Report on Form 8-K dated September 8, 2016)  

4.1 

  Description of Common Stock (incorporated by reference to Exhibit 4.1 to the Company’s Annual Report on 

Form 10-K filed on February 13, 2020) 

10.1 

  Net  Smelter  Returns  Royalty  Agreement,  dated  effective  January  7,  2010,  among  Kennecott  Exploration 
Company, Kennecott Arctic Company, Alaska Gold Company, and NovaGold Resources Inc. (incorporated by 
reference to Exhibit 99.1 to the Company’s Report on Form 6-K filed on April 25, 2012) 

10.2 

  Exploration Agreement and Option to Lease, dated October 19, 2011, between NovaCopper US Inc. and NANA 
Regional Corporation, Inc. (incorporated by reference to Exhibit 99.1 to the Company’s Report on Form 6-K 
filed on April 25, 2012) 

10.3 

  Option Agreement to Form Joint Venture, dated April 10, 2017, among the Company, NovaCopper US Inc. 
and South32 Group Operations Pty Ltd. (incorporated by reference to Exhibit 2.1 to the Company’s Current 
Report on Form 8-K/A filed on April 20, 2017) 

10.4 

  Amended and Restated Limited Liability Company Agreement of Ambler Metals LLC dated February 11, 2020 
(incorporated by reference to Exhibit 10.1 to the Company’s Current Report on Form 8-K filed on February 
18, 2020) 

10.5 

  NovaCopper  Inc.  2012  Restricted  Share  Unit  Plan  (incorporated  by  reference  to  Exhibit  10.11  to  the 

Company’s Annual Report on Form 10-K filed on February 12, 2013) 

10.6 

  NovaCopper Inc. 2012 Deferred Share Unit Plan (incorporated by reference to Exhibit 10.12 to the Company’s 

Annual Report on Form 10-K filed on February 12, 2013, File No. 001-35447) 

10.7 

  Form of NovaCopper Inc. Stock Option Agreement (incorporated by reference to Exhibit 4.5 to the Company’s  

Registration Statement on Form S-8 filed on April 27, 2012) 

10.8 

  NovaCopper  Inc.  Equity  Incentive  Plan  (incorporated  by  reference  to  Schedule  G  of  Exhibit  99.1  to  the 

Company’s Registration Statement on Form 40-F filed on March 1, 2012) 

10.9 

  Employment Agreement, dated April 20, 2020, between the Company and Tony Giardini (incorporated by 

reference to Exhibit 10.1 to the Company’s Current Report on Form 8-K filed on April 20, 2020)  

131 

     
 
 
 
 
 
   
 
 
   
 
 
 
 
 
   
 
 
   
 
 
   
 
 
   
 
 
   
 
 
   
 
 
   
 
 
   
 
 
   
 
 
   
10.10    Employment Agreement, dated November 5, 2012, between the Company and Elaine Sanders (incorporated 
by reference to Exhibit 10.5 to the Company’s Registration Statement on Form 10-K filed on February 12, 
2013) 

10.11 

  Equity Incentive Plan for Ambler Metals LLC Officers and Employees (incorporated by reference to the Revised 

Appendix D to the Company’s proxy statement filed April 30, 2021) 

21.1 

  Subsidiaries of the Registrant 

23.1 

Consent of PricewaterhouseCoopers LLP  

23.2 

Consent of Richard Gosse 

23.3 

Consent of Wood Canada Limited  

23.4 

Consent of Ausenco Engineering Canada Inc.  

23.5 

Consent of SRK Consulting (Canada) Inc.  

23.6 

Consent of Brown and Caldwell 

23.7 

  Consent of Wood Canada Limited 

31.1 

Certification of the Chief Executive Officer required by Rule 13a-14(a) or Rule 15d-14(a)  

31.2 

Certification of the Chief Financial Officer required by Rule 13a-14(a) or Rule 15d-14(a)  

32.1 

Certification of the Chief Executive Officer pursuant to 18 U.S.C. Section 1350  

32.2 

Certification of the Chief Financial Officer pursuant to 18 U.S.C. Section 1350  

96.1 

  Arctic Project S-K 1300 Technical Report Summary, Ambler Mining District, Alaska (incorporated by reference 

to the Company’s Current Report on Form 8-K filed on February 14, 2023) 

96.2 

  Technical Report Summary on the Initial Assessment of the Bornite Mineral Resource, Northwest Alaska, USA 

(incorporated by reference to the Company’s Current Report on Form 8-K filed on February 14, 2023) 

101 

  The  following  materials  from  Trilogy  Metals  Inc.’s  Annual  Report  on  Form  10-K  for  the  year  ended 
November 30, 2022, formatted in Inline XBRL (eXtensible Business Reporting Language): (i) the Consolidated 
Statements of Operations, (ii) the Consolidated Statements of Comprehensive Income (iii) the Consolidated 
Balance Sheets, (iv) the Consolidated Statements of Shareholders’ Equity, (v) the Consolidated Statements of 
Cash Flows, (vi) the Notes to the Consolidated Financial Statements, and (vii) Schedule II  – Valuation and 
Qualifying Accounts. 

104 

  Cover Page Interactive Data File (formatted as Inline XBRL and contained in Exhibit 101). 

(c) 

Financial Statement Schedules 

Schedule A – The Financial Statement of Ambler Metals LLC as of November 30, 2022. 

132 

 
 
 
 
 
 
 
 
   
 
 
 
   
 
 
 
   
 
 
 
   
 
 
 
   
 
 
 
   
 
 
 
   
 
 
 
 
 
 
   
 
 
 
   
 
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Schedule A  

Report of Independent Registered Public Accounting Firm 

To the Board of Ambler Metals LLC  

Opinion on the Financial Statements 
We have audited the accompanying balance sheets of Ambler Metals LLC (the Company) as of November 30, 2022 and 
2021, and the related statements of loss and comprehensive loss, changes in members' equity and cash flows for the 
years  then  ended  and  for  the  period  from  February  11,  2020  to  November  30,  2020,  including  the  related  notes 
(collectively referred to as the financial statements). In our opinion, the financial statements present fairly, in all material 
respects, the financial position of the Company as of November 30, 2022 and 2021, and the results of its operations and 
its cash flows for the years then ended and for the period from February 11, 2020 to November 30, 2020 in conformity 
with accounting principles generally accepted in the United States of America. 

Basis for Opinion 
These  financial  statements  are  the  responsibility  of  the  Company’s  management.  Our  responsibility  is  to  express  an 
opinion on the Company’s financial statements based on our audits. We are a public accounting firm registered with the 
Public Company Accounting Oversight Board (United States) (PCAOB) and are required to be independent with respect 
to  the  Company  in  accordance  with  the  U.S.  federal  securities  laws  and  the  applicable  rules  and  regulations  of  the 
Securities and Exchange Commission and the PCAOB. 

We conducted our audits of these financial statements in accordance with the standards of the PCAOB. Those standards 
require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are 
free of material misstatement, whether due to error or fraud. 

Our  audits  included  performing  procedures  to  assess  the risks  of  material  misstatement  of  the  financial  statements, 
whether  due  to  error  or  fraud,  and  performing  procedures  that  respond  to  those  risks.  Such  procedures  included 
examining, on a test basis, evidence regarding the amounts and disclosures in the financial statements. Our audits also 
included evaluating the accounting principles used and significant estimates made by management, as well as evaluating 
the  overall  presentation  of  the  financial  statements.  We  believe  that  our  audits  provide  a  reasonable  basis  for  our 
opinion. 

Critical Audit Matters  
The  critical  audit  matter  communicated  below  is  a  matter  arising  from  the  current  period  audit  of  the  financial 
statements  that  was  communicated  or  required  to  be  communicated  to  the  audit  committee  and  that  (i)  relates  to 
accounts  or  disclosures  that  are  material  to  the  financial  statements  and  (ii)  involved  our  especially  challenging, 
subjective, or complex judgments. The communication of critical audit matters does not alter in any way our opinion on 
the financial statements, taken as a whole, and we are not, by communicating the critical audit matter below, providing 
a separate opinion on the critical audit matter or on the accounts or disclosures to which it relates. 

Assessment of impairment indicators for mineral properties 

As described in Notes 2 and 5 to the financial statements, management assesses the possibility of impairment in the 
carrying value of mineral properties whenever events or changes in circumstances indicate that the carrying value may 
not be recoverable (impairment indicators). The carrying value of the Company’s mineral properties was $30.9 million 
as of November 30, 2022. Management applies judgment to assess whether events or changes in circumstances indicate 
the carrying value of an asset may not be recoverable, giving rise to the requirement to conduct an impairment test. 
Events or changes in circumstances that could trigger an impairment test include (i) significant adverse changes in the 
business climate including significant decreases in copper, zinc, and other metal prices, or significant adverse changes in 

133 

 
  
  
 
 
 
 
 
legal factors, (ii) an accumulation of costs significantly in excess of the amount originally expected for the acquisition or 
construction of the mineral properties, and (iii) significant decreases in the market prices of the mineral properties. 

The principal considerations for our determination that performing procedures relating to the assessment of impairment 
indicators of mineral properties is a critical audit matter are that there was judgment by management when assessing 
whether  there  were  impairment  indicators  related  to  the  Company’s  mineral  properties,  specifically  in  regards  to 
assessing whether there were: (i) significant adverse changes in the business climate including significant decreases in 
copper,  zinc,  and  other  metal  prices,  or  significant  adverse  changes  in  legal  factors,  (ii)  an  accumulation  of  costs 
significantly in excess of the amount originally expected for the acquisition or construction of the mineral properties, 
and (iii) significant decreases in the market prices of the mineral properties. This in turn led to a high degree of auditor 
judgment  and  subjectivity  in  performing  procedures  to  evaluate  audit  evidence  relating  to  the  judgment  made  by 
management  in  their  assessment  of  impairment  indicators  that  could  give  rise  to  the  requirement  to  conduct  an 
impairment test. 

Addressing the matter involved performing procedures and evaluating audit evidence in connection with forming our 
overall opinion on the financial statements. These procedures included, among others, (i) evaluating whether there were 
significant adverse changes in the business climate including significant decreases in copper, zinc, and other metal prices 
by considering external market and industry data, (ii) evaluating whether there were significant adverse changes in legal 
factors  with  respect  to  title  matters  by  obtaining  on  a  sample  basis  evidence  to  support  the  rights  to  the  mineral 
properties, (iii) evaluating whether there were significant decreases in the market prices of the mineral properties by 
considering  prolonged  declines  in  Trilogy  Metals  Inc.’s  share  price,  and  (iv)  evaluating  whether  there  was  an 
accumulation of costs significantly in excess of the amount originally expected for the acquisition or construction of the 
mineral properties, or other factors that may indicate that the carrying values of the mineral properties may not  be 
recoverable, through consideration of evidence obtained in other areas of the audit. 

/s/PricewaterhouseCoopers LLP 

Chartered Professional Accountants 
Vancouver, Canada 
February 13, 2023 

We have served as the Company's auditor since 2020.  

134 

 
 
 
 
 
 
 
 
 
 
Ambler Metals LLC 
Balance Sheet 
As at November 30, 2022 and 2021 

November 30, 2022 
$ 

in thousands of US dollars 
November 30, 2021 
$ 

Assets 
Current assets 
Cash (note 3) 
Deposits and prepaid 
Current loan receivable (note 1,8) 
Accounts receivables and other assets 
Total current assets 

Right of use asset (note 7) 
Loan receivable (note 1,8) 
Property, plant and equipment (note 4) 
Mineral properties (note 5) 
Total assets 

Liabilities 
Current liabilities 
Accounts payable and accrued liabilities (note 6,8) 
Current lease liabilities (note 7) 
Total current liabilities 

Long term lease liabilities (note 7) 
Total liabilities 

Members' equity 
Owner contribution - South 32 
Owner contribution - Trilogy 
Accumulated deficit 
Total members' equity 
Total liabilities and members equity 

 80,755 
 814 
 — 
 8 
 81,577 

 651 
 — 
 922 
 30,899 
 114,049 

 3,664 
 240 
 3,904 

 431 
 4,335 

 145,051 
 31,257 
 (66,594) 
 109,714 
 114,049 

 61,205 
 621 
 19,029 
 2 
 80,857 

 877 
 36,326 
 557 
 30,757 
 149,374 

 4,148 
 224 
 4,372 

 671 
 5,043 

 145,000 
 31,206 
 (31,875) 
 144,331 
 149,374 

(See accompanying notes to the financial statements) 

135 

  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Ambler Metals LLC 
Statement of Loss and Comprehensive Loss 
For the Years Ended November 30 

Expenses 
Depreciation 
Corporate salaries and wages 
General and administrative 
Mineral property expense (note 5) 
Professional fees 
Foreign exchange (gain)/loss 
Total expenses 

Other items 
Interest income 
Loss and comprehensive loss for the year 

2022 
$ 

 113 
 1,664 
 738 
 32,083 
 792 
 15 
 35,405 

 (686) 
 34,719 

in thousands of US dollars 
February 11, 2020 - 
November 30, 2020 
$ 

 95 
 441 
 826 
 3,536 
 1,990 
 3 
 6,891 

 (1,180) 
 5,711 

 2021 
$ 

 77 
 2,381 
 991 
 22,720 
 1,047 
 6 
 27,222 

 (1,058) 
 26,164 

(See accompanying notes to the financial statements) 

136 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Ambler Metals LLC 
Statement of Changes in Members’ Equity 
For the Years Ended November 30 

Opening balance 
Loss for the period 
Balance - November 30, 2020 
Loss for the year 
Balance - November 30, 2021 
Owner contributions 
Loss for the year 
Balance - November 30, 2022 

Number of units 
outstanding   
 2,000,000 
 — 
 2,000,000 
 — 
 2,000,000 
 — 
 — 
 2,000,000 

Trilogy owner 
contribution 
$ 
 31,206 
 — 
 31,206 
 — 
 31,206 
 51 
 — 
 31,257 

In thousands of US dollars, except share amounts 
Total members' 
equity 
$ 
 176,206 
 (5,711) 
 170,495 
 (26,164) 
 144,331 
 102 
 (34,719) 
 109,714 

South32 owner 
contribution 
$ 
 145,000 
 — 
 145,000 
 — 
 145,000 
 51 
 — 
 145,051 

Deficit 
$ 
 — 
 (5,711) 
 (5,711) 
 (26,164) 
 (31,875) 
 — 
 (34,719) 
 (66,594) 

(See accompanying notes to the financial statements) 

137 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Ambler Metals LLC 
Statement of Cash Flows 
For the Years Ended November 30 

Cash flows from (used in) operating activities 
Loss for the year 
Depreciation 
Lease expense 
Lease payments 
Equity contribution by Trilogy 
Change in working capital 

Increase in deposits and prepaids 
Decrease (increase) in accounts receivable and other assets 
Increase (decrease) in accounts payable and accrued liabilities 

Interest earned on South32 loan 
Interest received on South32 loan 
Cash used in operating activities 

Cash flows from (used in) financing activities 
Cash contribution by South32  
Cash from financing activities 

Cash flows from (used in) investing activities 
Principle payment on South32 loan 
Property Staking 
Machinery and equipment 
Vehicles 
Computer hardware and software 
Furniture and equipment  
Cash from investing activities 

Increase (decrease) in cash 
Cash - beginning of the period 
Cash - end of year 

November 30, 2022 
$ 

in thousands of US dollars 
February 11, 2020 - 
November 30, 2020 
$ 

November 30, 2021 
$ 

 (34,719) 
 113 
 264 
 (263) 
 51 

 (193) 
 (6) 
 (484) 
 (628) 
 740 
 (35,125) 

 51 
 51 

 55,244 
 (142) 
 (321) 
 (47) 
 — 
 (110) 
 54,624 

 19,550 
 61,205 
 80,755 

 (26,164) 
 77 
 261 
 (243) 
 — 

 (78) 
 8 
 2,703 
 (1,043) 
 1,909   
 (22,570) 

 (5,711) 
 95 
 — 
 — 
 — 

 (543) 
 (10) 
 1,445 
 (978) 

 (5,702) 

 — 
 — 

 145,000 
 145,000 

 2,256 
 (52) 
 (67) 
 — 
 — 
 (35)  
 2,102 

 (20,468) 
 81,673 
 61,205 

 (57,500) 
 (118) 
 — 
 — 
 (7) 

 (57,625) 

 81,673 
 — 
 81,673 

(See accompanying notes to the financial statements) 

138 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Ambler Metals LLC 
Notes to Financial Statements 
expressed in U.S. dollars, unless otherwise noted 

1.    Organization & basis of presentation 

Ambler Metals LLC (the “Company” or “Joint Venture”), a Delaware limited liability  company, is a 50-50 joint venture 
between NovaCopper US Inc., a wholly owned subsidiary of Trilogy Metals Inc. (collectively “Trilogy”), and South32 USA 
Exploration Inc., a wholly owned subsidiary of South32 Limited (collectively “South32”). 

The Company is engaged in the exploration and development of mineral properties with a focus on the Upper Kobuk 
Mineral Projects (“UKMP”), including the Arctic and Bornite Projects located in Northwest Alaska in the United States of 
America (“US” or “USA”). 

On  February 11,  2020,  pursuant  to  a  contribution  agreement  among  Trilogy,  South32  and  the  Company  (the 
“Contribution Agreement”), Trilogy contributed to the Company all of Trilogy’s assets associated with the Upper Kobuk 
Mineral Projects ("UKMP") located in northwest  Alaska in exchange for a  50% membership interest  in the Company. 
Simultaneously, South32 contributed $145 million cash in exchange for a 50% membership interest in the Company. 

The  operations  and  governance  of  the  Joint  Venture  are  provided  for  in  the  Company’s  Limited  Liability  Company 
Agreement dated February 11, 2020 (the “LLC Agreement”). 

The mining rights, deposits and property, plant and equipment contributed to the Company from Trilogy are recognized 
at  Trilogy’s  historical  carrying  value  on  the  date  of  contribution.  The  contributions,  including  noncash  contributions, 
made to the Company by each respective member on February 11, 2020 were as follows: 

Respective contributions to the Joint Venture 

Intangible assets: 
Mining rights 

Trilogy contributed intangible assets 

Tangible assets: 

Deposits 
Property, plant and equipment 

Trilogy contributed tangible assets 

Cash 

South32 contributed cash 

Total capital contributed at inception 

in thousands of US dollars 
$ 

 30,587 
 30,587 

 1 
 618 
 619 

 145,000 
 145,000 
 176,206 

As  a  result  of  these  transactions,  Trilogy  and  South32  each  have  equal  interests  in  the  Company  and  have  equal 
representation on the Board of the Company. 

Following the formation of the Joint Venture, on March 17, 2020 the Company loaned South32 $57.5 million secured by 
South32’s membership interest in Ambler Metals and guaranteed by South32 International Investment Holdings Pty Ltd., 
a wholly owned subsidiary of South32. The loan had a 7-year maturity date and was recorded at amortized cost.  The 
loan repayment terms were such that quarterly payments became due from South32 on a quarterly basis beginning in 
2Q 2021 based on forecasted expenditures.  On June 21, 2022, South32 paid the full balance of the loan, consisting of 
$53.0 million principal and $0.5 million interest.  See note 8 for additional information. 

139 

 
 
 
 
 
 
 
 
 
 
 
Ambler Metals LLC 
Notes to Financial Statements 
expressed in U.S. dollars, unless otherwise noted 

The  financial  statements  have  been  prepared  by  management  in  conformity  with  generally  accepted  accounting 
principles in the United States (“U.S. GAAP”) on a going concern basis, which contemplates the realization of assets and 
the discharge of liabilities in the normal course of business for the foreseeable future. 

These financial statements have been prepared pursuant to Rule 3-09 of SEC Regulation S-X for inclusion in Trilogy’s 10-
K/A, as the Company is an equity investee of Trilogy. 

2.    Summary of significant accounting policies 

Property, plant and equipment 

Plant and equipment are recorded at cost and depreciation begins when the asset is  put into service. Depreciation is 
calculated on a straight-line basis over the respective assets’ estimated useful lives. Depreciation periods by asset class 
are: 

Computer hardware and software 
Machinery and equipment 
Furniture and equipment 
Vehicles 
Leasehold improvements 

Mineral properties and development costs 

3 years 
3 - 10 years 
5 - 10 years 
3 years 
lease term 

All  direct  costs  related  to  the  acquisition  of  mineral  property  interests  are  capitalized.  Mineral  property  exploration 
expenditures  are  expensed  when  incurred.  When  it  has  been  established  that  a  mineral  deposit  is  commercially 
mineable,  an  economic  analysis  has  been  completed  and  permits  are  obtained,  the  costs  subsequently  incurred  to 
develop a mine on the property prior to the start of mining operations are capitalized. Capitalized costs will be amortized 
following  commencement  of  production  using  the  unit  of production  method  over  the  estimated  life  of  proven  and 
probable reserves. 

Impairment of long-lived assets 

Management assesses the possibility of impairment in the carrying value of long-lived assets whenever events or changes 
in circumstances indicate that the carrying amounts of the asset or asset group may not be recoverable. Management 
applies judgment to assess impairment indicators that could give rise to the requirement to conduct a formal impairment 
test. Events and circumstances that could trigger an impairment test include, but are not limited to, significant adverse 
changes  in  the  business  climate  including  significant  decreases  to  copper,  zinc  and  other  metal  prices  or  significant 
adverse changes in legal factors, an accumulation of costs significantly in excess of the amount originally expected for 
the acquisition or construction of the long-lived asset, and significant decreases in the market prices for long-lived assets.  
Management  calculates the  estimated undiscounted future net  cash flows relating to  the asset  or asset  group using 
estimated  future  prices,  proven  and  probable  reserves  and  other  mineral  resources,  and  operating,  capital  and 
reclamation costs. When the carrying value of an asset exceeds the related undiscounted cash flows, the asset is written 
down  to  its  estimated  fair  value,  which  is  usually  determined  using  discounted  future  cash  flows.  Management’s 
estimates  of  mineral  prices,  mineral  resources,  foreign  exchange  rates,  production  levels,  operating,  capital  and 
reclamation costs are subject to risk and uncertainties that may affect the determination of the recoverability of the 
long-lived asset. It is possible that material changes could occur that may adversely affect management’s estimates. 

140 

 
 
 
 
 
 
 
 
 
Ambler Metals LLC 
Notes to Financial Statements 
expressed in U.S. dollars, unless otherwise noted 

Leases 

We determine if a contractual arrangement represents or contains a lease at inception. Operating leases are included in 
right of use assets and lease liabilities on our balance sheet. Assets under finance leases are included in property, plant 
and equipment and the related lease liabilities in lease liabilities on our balance sheet. 

Operating and finance lease right of use assets  and lease liabilities are recognized based on the present value of the 
future lease payments over the lease term at the commencement date. When the rate implicit to the lease cannot be 
readily  determined,  we  utilize  the  incremental  borrowing  rate  in  determining  the  present  value  of  the  future  lease 
payments.  The  incremental  borrowing  rate  is  the  rate  of  interest  our  Company  would  have  to  pay  to  borrow  on  a 
collateralized basis over a similar term and the amount equal to the lease payments in a similar economic environment. 

The operating lease expenses are recognized on a straight-line basis over the lease term. 

Income taxes 

The Company is not a taxable entity for income tax purposes. Accordingly, no recognition is given to income taxes for 
financial reporting purposes. Tax on the net income (loss) of the Company is borne by the owners through the allocation 
of taxable income (loss). Net income for financial statement purposes may differ significantly from taxable income for 
the owners as a result of differences between the tax basis and financial reporting basis of assets and liabilities and the 
taxable income allocation requirements under the shareholders agreement. 

Financial instruments 

Loans and receivables are recorded initially at fair value, net of transaction costs incurred, and subsequently at amortized 
cost  using  the  effective  interest  rate  method.  Loans  and  receivables  consist  of  cash,  deposits,  and  loans  receivable.  
Estimated  future  credit  losses  are  based  on  historical  credit  loss  experience  and  forward-looking  considerations.  
Individual receivables are written off when management deem them to be uncollectible.  Further details on credit risk 
are disclosed in note 9.  

Other financial liabilities include accounts payable and accrued liabilities. 

Translation of foreign currencies 

Foreign denominated monetary assets and liabilities are translated into United States dollars at the exchange rate in 
effect at the balance sheet date, and non-monetary assets and liabilities at the exchange rate in effect at the time of 
acquisition or issue. Income and expenses are translated at rates approximating the exchange rate in effect at the time 
of transactions. Exchange gains or losses arising on translation are included in income or loss for the period. 

The functional currency of the Company and the Company’s reporting currency is the United States dollar. 

3.    Cash 

As  of  November  30,  2022,  included  in  cash  is  $0.4  million  denominated  in  Canadian  dollars  and  $80.5  million  
denominated in United States dollars. 

141 

Ambler Metals LLC 
Notes to Financial Statements 
expressed in U.S. dollars, unless otherwise noted 

4.  Property, plant and equipment 

A summary of property, plant and equipment as of November 30, 2022 and November 30, 2021, is as follows: 

in thousands of US dollars 

Machinery 
and 
equipment 
$ 
 1,057 
 — 
 (456) 
 (135) 
 466 
 601 
 321 
 (206) 
 716 

Computer 
hardware 
and software 
$ 
 12 
 — 
 — 
 (9) 
 3 
 12 
 — 
 (12) 
 — 

Furniture and 
Equipment 
$ 
 — 
 35 
 — 
 (1) 
 34 
 35 
 110 
 (9) 
 136 

Vehicles  
$ 
 — 
 67 
 — 
 (13) 
 54 
 67 
 47 
 (44) 
 70 

Total 
$ 
 1,069 
 102 
 (456) 
 (158) 
 557 
 715 
 478 
 (271) 
 922 

Cost at November 30, 2020 
Additions 
Assets derecognized 
Accumulated Depreciation 
Net book value at November 30, 2021 
Cost at November 30, 2021 
Additions 
Accumulated Depreciation 
Net book value at November 30, 2022 

5.    Mineral properties 

November 30, 
2020 
$ 
 26,705 
 4,000 
 30,705 

Additions 
$ 
 52 
 — 
 52 

November 30, 
2021 
$ 
 26,757 
 4,000 
 30,757 

in thousands of US dollars 
November 30, 
2022 
$ 
 26,899 
 4,000 
 30,899 

Additions 
$ 
 142 
 — 
 142 

Ambler 
Bornite 

a)  Ambler 

On  February 11,  2020,  the  Ambler  lands  in  Northwest  Alaska,  which  contains  the  copper-zinc-lead-gold-silver  Arctic 
Project and other mineralized targets within the volcanogenic massive sulfide belt, were contributed to Ambler Metals 
LLC pursuant to the Contribution Agreement. The Ambler lands are subject to a 1% net smelter return (“NSR”) royalty 
that can be purchased at any time for a one-time payment of $10 million. 

Mineral property costs of approximately $142 thousand were added to the Ambler land holdings during the period ended 
November 30, 2022.   

b)  Bornite 

On February 11, 2020, the exclusive right to explore and the non-exclusive right to access and enter on the Bornite lands, 
and lands deeded to NANA Regional Corporation, Inc. (“NANA”) through the Alaska Native Claims Settlement Act, located 
adjacent to the Ambler lands in Northwest Alaska, were contributed to Ambler Metals LLC pursuant to the Contribution 
Agreement. 

142 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Ambler Metals LLC 
Notes to Financial Statements 
expressed in U.S. dollars, unless otherwise noted 

Upon a decision to proceed with construction of a mine on the Ambler or Bornite lands, NANA maintains the right to 
purchase between a 16%-25% ownership interest in the mine or retain a 15% net proceeds royalty which is payable after 
Ambler  Metals LLC has recovered certain historical costs, including capital and cost  of capital. Should NANA elect to 
purchase an ownership interest, consideration will be payable equal to all historical costs incurred on the properties at 
the elected percentage, not to be less than zero. The parties would form a joint venture and be responsible for all future 
costs, including capital costs of the mine based on their pro-rata share. 

NANA would also be granted a net smelter return royalty of between 1% and 2.5% upon the execution of a mining lease 
or a  surface use agreement,  the amount  of  which  is determined by the classification of land from  which  production 
originates. 

c)  Mineral properties expense 

The following table summarizes mineral properties expense incurred for the year ended November 30, 2022, November 
30, 2021 and November 30, 2020.  Lease expense for the warehouse previously classified as general and administrative 
of approximately $81 thousand and $48 thousand for the years ended November 30, 2021 and November 30,  2020, 
respectively,  were  reclassified  to  mineral  property  expense  under  project  support  in  order  to  align  with  the  current 
period presentation. 

Ambler Access Project 
Community 
Drilling 
Engineering 
Environmental 
Geochemistry and geophysics 
Land and permitting 
Project support 
Safety and risk 
Wages and benefits 
Mineral property expense 

6.    Accounts payable and accrued liabilities 

Accounts payable 
Accrued demobilization charges 
Accrued salaries and vacation 
Accrued liabilities 
Accounts payable and accrued liabilities 

November 30, 2022 
$ 
 6,822 
 219 
 7,396 
 2,002 
 692 
 1,172 
 800 
 8,613 
 562 
 3,805 
 32,083 

November 30, 2021 
$ 
 2,880 
 114 
 3,898 
 1,508 
 621 
 975 
 1,266 
 8,432 
 230 
 2,796 
 22,720 

in thousands of US dollars 
February 11, 2020 - 
November 30, 2020 
$ 
 261 
 — 
 444 
 645 
 245 
 171 
 232 
 368 
 — 
 1,170 
 3,536 

November 30, 2022 
$ 
 1,031 
 — 
 845 
 1,788 
 3,664 

in thousands of US dollars 
November 30, 2021 
$ 
 844 
 113 
 1,082 
 2,109 
 4,148 

143 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Ambler Metals LLC 
Notes to Financial Statements 
expressed in U.S. dollars, unless otherwise noted 

7.    Leases 

(a)  Right of use assets 

Opening balance 
Recognition of right of use asset 
Amortization 
Right of use asset 

November 30, 2022 
$ 
 877 
 — 
 (226) 
 651 

in thousands of US dollars 
November 30, 2021 
$ 
 51 
 1,046 
 (220) 
 877 

In December 2020, the Company commenced a lease for their headquarters office in Anchorage, Alaska and recognized 
the  right  of  use  asset  approximately  $816  thousand.    In  August  2021,  the  Company  commenced  a  new  lease  for  a 
warehouse in Fairbanks, Alaska and recognized the right of use asset of approximately $231 thousand.  

(b)  Lease liabilities 

The headquarters and warehouse leases are operating leases ending in 2025 and 2024, respectively. There is an option 
to renew for both lease agreements. 

Lease expense for the headquarters is recorded within general and administrative expense and for the warehouse is 
recorded within mineral property expense and was comprised of the following components: 

Operating lease costs 
Variable lease costs 
Operating lease costs 

November 30, 2022 
$ 
 264 
 3 
 267 

in thousands of US dollars 
November 30, 2021 
$ 
 261 
 — 
 261 

Variable lease costs consist primarily of the Company’s portion of common area maintenance fees including taxes. As of 
November 30, 2022, variable costs were approximately $3 thousand. 

As of November 30, 2022, the remaining lease term was 37 months for the headquarters office and 20 months for the 
warehouse. 

Supplemental cash and non-cash information relating to our leases during the period ended November 30, 2022, are as 
follows: 

• 

Cash  paid  for  amounts  included  in  the  measurement  of  lease  liabilities  was  approximately  $263 
thousand. 

•  Non-cash amounts included in the measurement of lease liabilities was $nil. 

144 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Ambler Metals LLC 
Notes to Financial Statements 
expressed in U.S. dollars, unless otherwise noted 

Future minimum payments relating to the lease recognized in our balance sheet as of November 30, 2022 are as follows: 

2022 
2023 to 2025 
Total undiscounted lease payments 
Effects of discounting 
Present value of lease payments recognized as lease liability 

8.    Related party transactions 

in thousands of US dollars 
November 30, 2022 
$ 
 — 
 716 
 716 
 (45) 
 671 

During the year ended November 30, 2022, the Company earned interest of $0.6 million (2021 - $1 million), from the 
loan to South32 and received payments on the loan of $56 million, of which, $0.7 million applied to interest and $55.2 
million applied to principal.   

9.    Financial risk management 

(a)  Currency risk 

Currency risk is the risk of a fluctuation in financial asset  and liability settlement amounts due to a change in foreign 
exchange rates. The Company operates in the United States and holds a bank account denominated in Canadian currency 
to facilitate payments to Canadian vendors, as necessary. The Company’s exposure to the currency risk at November 30, 
2022 is limited to the Canadian dollar balances consisting of cash of approximately CDN $351 thousand and accounts 
payable of CDN $74 thousand. Based on a 10% change in the US-Canadian exchange rate, assuming all other variables 
remain constant, the Company’s net change would be approximately $22 thousand. 

(b)  Credit risk 

Credit  risk  is  the  risk  of  an  unexpected  loss  if  a  customer  or  third  party  to  a  financial  instrument  fails  to  meet  its 
contractual obligations. The Company holds cash with a financial institution that is federally insured through FDIC. The 
Company’s exposure to credit risk is equal to the balance of cash recorded in the financial statements. 

(c)  Liquidity risk 

Liquidity risk is the risk that the Company will encounter difficulties raising funds to meet its financial obligations as they 
fall  due.  The  Company  is  in  the  exploration  stage  and  does  not  have  cash  inflows  from  operations;  therefore,  the 
Company manages liquidity risk through the terms of the LLC Agreement. 

145 

 
 
 
 
 
Ambler Metals LLC 
Notes to Financial Statements 
expressed in U.S. dollars, unless otherwise noted 

Contractually obligated cash flow requirements as of November 30, 2022 are as follows:  

Accounts payable and accrued liabilities 
Warehouse and office lease 

(d)  Interest rate risk 

Total  
$ 

<1 year 
$ 

1-2 year 
$ 

 3,664 
 716 
 4,380 

 3,664 
 266 
 3,930 

 — 
 243 
 243 

2-5 years 
$ 

in thousands of US dollars 
There 
after 
$ 
 — 
 — 
 — 

 — 
 207 
 207 

Interest rate risk is the risk that the fair value or future cash flows of a financial instrument will fluctuate because of 
changes in market interest rates. The Company is exposed to interest rate risk with respect to interest earned on cash. 
Based on cash balances as of November 30, 2022, a 1% change in interest rates would result in a negligible change in 
cash, over a 12-month period, assuming all other variables remain constant. 

As we are currently in the exploration phase, none of our financial instruments are exposed to commodity price risk; 
however,  the  ability  for  our  Owners  to  obtain  long-term  financing  and  its  economic  viability  could  be  affected  by 
commodity price volatility. 

10.    Commitments and contingencies 

The Company has commitments with respect to a warehouse and office lease requiring future minimum lease payments 
as summarized in note 7. 

11.    Members’ equity 

The  Company  has  been  established  as  a  limited  liability  company.  Under  the  terms  of  the  LLC  Agreement,  unless 
otherwise provided for in the LLC Agreement, all membership interests are entitled to the same benefits, rights, duties 
and obligations and vote on all matters. 

The  Company  is  authorized  to  establish  a  capital  account  for  each  member  equal  to  that  member’s  initial  capital 
contribution,  represented  by  units.  The  units  are  voting  and  subject  to  transfer  restrictions  as  defined  in  the  LLC 
Agreement. As of November 30, 2022 and 2021,  the Company had 2 million  units, with each of South32 and Trilogy 
owning 1 million units each, in exchange for the contributions made to the Company at inception. 

As described in the LLC Agreement, under certain circumstances a member shall have the right to transfer to any third 
party all or any part of its Membership Interest or any economic interest, (including its right to receive distributions of 
cash  or  property  from  the  Company).  Any  such  transfer  is  subject  to  the  satisfaction  of  certain  conditions,  and  the 
relevant purchase price is determined pursuant to specific formulas, all as set forth in the LLC Agreement. 

146 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Item 16.  FORM 10-K SUMMARY 

None. 

147 

 
 
Pursuant to the requirements of Section 13 or 15(d) of the Securities Exchange Act of 1934, the registrant has duly caused 
this report to be signed on its behalf by the undersigned, thereunto duly authorized. 

SIGNATURES 

TRILOGY METALS INC. 

By:  /s/ Tony Giardini 

Name: Tony Giardini 
Title:  President and Chief Executive Officer 

Date: February 14, 2023 

Pursuant to the requirements of the Securities Exchange Act of 1934, this report has been signed below by the following 
persons on behalf of the registrant and in the capacities and on the dates indicated: 

Signature 

Title 

Date 

/s/ Tony Giardini 
Tony Giardini 

/s/ Elaine Sanders 
Elaine Sanders 

/s/ James Gowans 
James Gowans 

/s/ William Hayden 
William Hayden 

/s/ William Hensley 
William Hensley 

/s/ Gregory Lang 
Gregory Lang 

/s/ Kalidas Madhavpeddi 
Kalidas  Madhavpeddi 

/s/ Janice Stairs 
Janice Stairs 

/s/ Diana Walters 
Diana Walters 

  President and Chief Executive Officer  

  February 14, 2023 

(Principal Executive Officer) and Director 

  February 14, 2023 

  February 14, 2023 

  February 14, 2023 

  February 14, 2023 

  February 14, 2023 

  February 14, 2023 

  February 14, 2023 

  February 14, 2023 

  Chief Financial Officer (Principal Financial 
  Officer and Principal Accounting Officer) 

  Director 

  Director 

  Director 

  Director 

  Director  

  Director 

  Director 

148 

 
 
 
 
 
 
 
 
 
  
 
  
 
 
 
 
 
 
   
  
   
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Name of Subsidiary 

       Jurisdiction of Organization 

SUBSIDIARIES OF THE REGISTRANT 

NovaCopper US Inc. (dba Trilogy Metals US) 

 Delaware 

Ambler Metals LLC (50% owned by NovaCopper US Inc.) 

 Delaware 

995 Exploration Inc. 

  Delaware 

Exhibit 21.1 

 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM 

Exhibit 23.1 

We hereby consent to the incorporation by reference in the Registration Statements on Form S-8 (No. 333-181020, No. 333-188950, 
No. 333-205102, No. 333-208149, No. 333-234417, and No. 333-257095) of Trilogy Metals Inc. of (i) our report dated February 13, 
2023, relating to the consolidated financial statements of Trilogy Metals Inc.,  and (ii) our report dated February 13, 2023 relating to 
the financial statements of Ambler Metals LLC, both of which appears in this Form 10-K. 

/s/ PricewaterhouseCoopers LLP 

Chartered Professional Accountants 

Vancouver, Canada 

February 13, 2023 

 
 
 
 
 
 
 
 
 
 
 
 
 
CONSENT OF RICHARD GOSSE 

Exhibit 23.2 

I hereby consent to the inclusion in this Annual Report on Form 10-K, which is being filed with the United States Securities and Exchange 
Commission, of references to my name and to the use of the  scientific and technical information included in Trilogy Metals Inc.’s 
Annual Report on Form 10-K for the year ended November 30, 2022. 

I also consent to the incorporation by reference in Trilogy Metals Inc.’s Registration Statements on Form S-8 (No. 333-181020, No. 
333-188950, No. 333-205102, No. 333-208149, No. 333-234417 and No. 333-257095) and the Registration Statement on Form S-3 
(No. 333-234164) of references to my name and to the use of the scientific and technical information included in the Annual Report 
on Form 10-K as described above. 

DATED: February 13, 2023 

/s/ Richard Gosse 
Name: Richard Gosse 

 
 
  
 
  
 
  
 
 
 
  
 
  
  
  
 
CONSENT OF WOOD CANADA LIMITED 

Exhibit 23.3 

In connection with the Trilogy Metals Inc. Annual Report on Form 10-K for the year ended November 30, 2022 and 
any amendments or supplements and/or exhibits thereto (collectively, the “Form 10-K”), the undersigned consents 
to: 

i. 

ii. 

iii. 

the filing and use of the technical report summary titled Arctic Project, Technical Report Summary, Ambler 
Mining District, Alaska, current as of November 30, 2022 (the “Arctic TRS”) as referenced in the form 10-K; 

the use of and references to our name, including our status as a third-party firm comprising mining experts, 
(as described in Subpart 1300 of Regulation S-K promulgated by the Securities and Exchange Commission), 
in connection with the TRS, Form 10-K and the Registration Statements on Form S-8 (No. 333-257095, No. 
333-234417, No. 333-208149, No. 333-205102, No. 333-188950 and No. 333-181020) (the “Registration 
Statements”); and  

any extracts or summaries of the Arctic TRS included or incorporated by reference in the Form 10-K and the 
use of any information derived, summarized, quoted or referenced from the Arctic TRS, or portions thereof, 
that was prepared by us, that we supervised the preparation of, and/or that was reviewed and approved 
by us, that is included or incorporated by reference in the Form 10-K and which is incorporated by reference 
in the Registration Statements.  

Wood Canada Limited is responsible for authoring, and this consent pertains to, Chapters 1.5, 1.6, 1.7, 1.8, 1.10, 
1.11, 1.12, 1.14.5, 1.20.1, 1.20.2, 2.3, 2.4, 2.5, 2.6, 6, 7.1, 7.2.1, 7.2.2, 7.2.3, 7.2.5, 7.2.6, 7.2.7, 7.2.8, 8.1.1, 8.1.3, 
8.1.4, 8.1.5, 8.1.6, 8.2.1, 8.2.2, 8.2.3, 8.2.4, 8.3, 9, 11, 12, 13.1, 13.2, 13.3, 13.4, 13.5, 13.6, 13.7, 13.8, 13.10, 18.1.6, 
18.2.2, 22.3, 22.4, 22.6, 22.7, 22.8, 23.2, 23.3, 25 of the Arctic TRS. 

13 February 2023 

/s/ Wood Canada Limited 
Wood Canada Limited 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Ausenco Engineering Canada Inc., 
1050 West Pender Street, Suite 1200, 
Vancouver, British Columbia, V6E 3S7 

Exhibit 23.4 

CONSENT OF AUSENCO ENGINEERING CANADA INC. 

In connection with the Trilogy Metals Inc. Annual Report on Form 10-K for the year ended November 30, 2022 and 
the exhibits thereto (collectively, the “Form 10-K”), the undersigned consents to: 

i. 

ii. 

iii. 

the filing and use of the technical report summary titled “Arctic Project, Technical Report Summary, Ambler 
Mining District, Alaska”, current as of November 30, 2022 (the “Arctic TRS”) as referenced in the Form 10-
K; 

the use of and references to our name, including our status as an expert, in connection with the TRS, Form 
10-K and the Registration Statements on Form S-8 (No. 333-257095, No. 333-234417, No. 333-208149, No. 
333-205102, No. 333-188950 and No. 333-181020) (the “Registration Statements”); and  

any extracts or summaries of the TRS included or incorporated by reference in the Form 10-K and the use 
of any information derived, summarized, quoted or referenced from the TRS, or portions thereof, that was 
prepared by us, that we supervised the preparation of, and/or that was reviewed and approved by us, that 
is included or incorporated by reference in the Form 10-K and which is incorporated by reference in the 
Registration Statements.  

Ausenco Engineering Canada Inc. is responsible for authoring, and this consent pertains to, the following Sections of 
the TRS: 1.1, 1.3, 1.4, 1.9, 1.13, 1.14.1, 1.14.2, 1.14.3, 1.14.4, 1.15, 1.17, 1.18, 1.19, 1.20.8, 1.20.9, 1.20.10, 2, 3.1, 
3.2, 3.10, 4, 5.3.8, 10, 14, 15.1, 15.2, 15.3, 15.4, 15.5, 15.6, 15.7, 15.10.8, 15.12, 15.13, 15.14, 15.15, 15.16, 16, 18.1.1, 
18.1.2, 18.1.3, 18.1.4, 18.1.5, 18.1.7, 18.1.9, 18.1.10, 18.1.11, 18.1.12, 18.1.13, 18.1.14, 18.2.1, 18.2.3, 18.2.4, 18.2.5, 
18.2.6, 19, 21, 22.1, 22.5, 22.9, 22.10, 22.12, 22.13, 22.14, 22.15, 22.16, 22.17.8, 22.17.9, 23.1, 23.9, 23.10, 23.11, 
24, 25.1, 25.3, 25.5. 

Dated February 13, 2023 

/s/ Ausenco Engineering Canada Inc. 
Ausenco Engineering Canada Inc. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
CONSENT OF SRK CONSULTING (CANADA) INC. 

Exhibit 23.5 

In connection with the Trilogy Metals Inc. Annual Report on Form 10-K for the year ended November 30, 2022 and 
any amendments or supplements and/or exhibits thereto (collectively, the “Form 10-K”), the undersigned consents 
to: 

i. 

ii. 

iii. 

the filing and use of the technical report summary titled Arctic Project, Technical Report Summary, Ambler 
Mining District, Alaska, current as of November 30, 2022 (the “Arctic TRS”) as referenced in the form 10-K; 

the use of and references to our name, including our status as an expert or “qualified person”, (as described 
in Subpart 1300 of Regulation S-K promulgated by the Securities and Exchange Commission), in connection 
with the TRS, Form 10-K and the Registration Statements on Form S-8 (No. 333-257095, No. 333-234417, 
No. 333-208149, No. 333-205102, No. 333-188950 and No. 333-181020) (the “Registration Statements”); 
and  

any extracts or summaries of the Arctic TRS included or incorporated by reference in the Form 10-K and the 
use of any information derived, summarized, quoted or referenced from the Arctic TRS, or portions thereof, 
that was prepared by us, that we supervised the preparation of, and/or that was reviewed and approved 
by us, that is included or incorporated by reference in the Form 10-K and which is incorporated by reference 
in the Registration Statements.  

13 February 2023 

/s/ SRK Consulting (Canada) Inc. 
SRK Consulting (Canada) Inc. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
BROWN AND CALDWELL 
201 NORTH CIVIC DRIVE, SUITE 300, 
WALNUT CREEK, CA 94596, USA 

Exhibit 23.6 

CONSENT OF BROWN AND CALDWELL 

In connection with the Trilogy Metals Inc. Annual Report on Form 10-K for the year ended November 30, 2022 and any amendments 
or supplements and/or exhibits thereto (collectively, the “Form 10-K”), the undersigned consents to: 

i. 

ii. 

iii. 

the filing and use of the technical report summary titled “Arctic Project, Technical Report Summary, Ambler Mining District, 
Alaska” current as of November 30, 2022 (the “Arctic TRS”), as referenced in the form 10-K; 
the use of and references to our name, including our status as an expert or “qualified person”, (as described in Subpart 1300 
of Regulation S-K promulgated by the Securities and Exchange Commission), in connection with the TRS, Form 10-K and the 
Registration Statements on Form S-8 (No. 333-257095, No. 333-234417, No. 333-208149, No. 333-205102, No. 333-188950 
and No. 333-181020) (the “Registration Statements”); and  
any  extracts  or  summaries  of  the  Arctic  TRS  included  or  incorporated  by  reference  in  the  Form  10-K  and  the  use  of  any 
information derived, summarized, quoted or referenced from the Arctic TRS, or portions thereof, that was prepared by us, 
that we supervised the preparation of, and/or that was reviewed and approved by us, that is included or incorporated by 
reference in the Form 10-K and which is incorporated by reference in the Registration Statements.  

DENNIS FINK / BROWN AND CALDWELL is responsible for authoring, and this consent pertains to, the following Sections of the Arctic 
TRS related to the water treatment plant: 1.14.9, 1.20.7, 2.3, 15.9, 17.3.4, 17.3.6.2, 18.1.9.1, 18.2.6, and 25.  

Dated February 12, 2023 

/s/ BROWN AND CALDWELL 
BROWN AND CALDWELL 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
CONSENT OF WOOD CANADA LIMITED 

Exhibit 23.7 

In connection with the Trilogy Metals Inc. Annual Report on Form 10-K for the year ended November 30, 2022 and any 
amendments or supplements and/or exhibits thereto (collectively, the “Form 10-K”), the undersigned consents to: 

i. 

ii. 

iii. 

the filing and use of the technical report summary titled Technical Report Summary on the Initial 
Assessment of the Bornite Mineral Resource, Northwest Alaska, current as of November 30, 2022 (the 
“Bornite TRS”) as referenced in the Form 10-K; 

the use of and references to our name, including our status as a third-party firm comprising mining 
experts, (as described in Subpart 1300 of Regulation S-K promulgated by the Securities and Exchange 
Commission), in connection with the TRS, Form 10-K and the Registration Statements on Form S-8 (No. 
333-257095, No. 333-234417, No. 333-208149, No. 333-205102, No. 333-188950 and No. 333-181020) 
(the “Registration Statements”); and 

any extracts or summaries of the Bornite TRS included or incorporated by reference in the Form 10-K and 
the use of any information derived, summarized, quoted or referenced from the Bornite TRS, or portions 
thereof, that was prepared by us, that we supervised the preparation of, and/or that was reviewed and 
approved by us, that is included or incorporated by reference in the Form 10-K and which is incorporated 
by reference in the Registration Statements. 

Wood Canada Limited is responsible for authoring, and this consent pertains to, all Chapters of the Bornite TRS. 

13 February 2023 

/s/ Wood Canada Limited 
Wood Canada Limited 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
CERTIFICATION OF CHIEF EXECUTIVE OFFICER 

PURSUANT TO RULE 13a-14(a) OF THE 

SECURITIES EXCHANGE ACT OF 1934 

Exhibit 31.1 

I, Tony Giardini, certify that: 

1. I have reviewed this annual report on Form 10-K of Trilogy Metals Inc.; 

2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary 
to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the 
period covered by this report; 

3. Based on my knowledge, the financial statements, and other financial information included in this report, fairly present in all material 
respects the financial condition, results of operations and cash flows of the registrant as of, and for, the periods presented in this report; 

4. The registrant’s other certifying officer(s) and I are responsible for establishing and maintaining disclosure controls and procedures 
(as defined in Exchange Act Rules 13a-15(e) and 15d-15(e)) and internal control over financial reporting (as defined in Exchange Act 
Rules 13a-15(f) and 15d-15(f)) for the registrant and have: 

(a) Designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under 
our supervision, to ensure that material information relating to the registrant, including its consolidated subsidiaries, is made known to 
us by others within those entities, particularly during the period in which this report is being prepared; 

(b)  Designed  such  internal  control  over  financial  reporting,  or  caused  such  internal  control  over  financial  reporting  to  be 
designed under our supervision, to provide reasonable assurance regarding the reliability of financial reporting and the preparation of 
financial statements for external purposes in accordance with generally accepted accounting principles; 

(c) Evaluated the effectiveness of the registrant’s disclosure controls and procedures and presented in this report our conclusions 
about  the  effectiveness  of  the  disclosure  controls  and  procedures,  as  of  the  end of  the  period  covered by  this  report based  on  such 
evaluation; and 

(d)  Disclosed  in  this  report  any  change  in  the  registrant's  internal  control over  financial  reporting  that  occurred  during  the 
registrant's most recent fiscal quarter (the registrant's fourth fiscal quarter in the case of an annual report) that has materially affected, 
or is reasonably likely to materially affect, the registrant's internal control over financial reporting; and 

5. The registrant’s other certifying officer(s) and I have disclosed, based on our most recent evaluation of internal control over financial 
reporting, to the registrant’s auditors and the audit committee of the registrant’s board of directors (or persons performing the equivalent 
functions): 

(a) All significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting 
which are reasonably likely to adversely affect the registrant’s ability to record, process, summarize and report financial information; 
and 

(b)  Any  fraud,  whether  or  not  material,  that  involves  management  or  other  employees  who  have  a  significant  role  in  the 

registrant’s internal control over financial reporting. 

Date: February 14, 2023 

  By: 

/s/ Tony Giardini 
Tony Giardini 
Chief Executive Officer 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
  
 
 
 
CERTIFICATION OF CHIEF FINANCIAL OFFICER 

PURSUANT TO RULE 13a-14(a) OF THE 

SECURITIES EXCHANGE ACT OF 1934 

Exhibit 31.2 

I, Elaine Sanders, certify that: 

1. I have reviewed this annual report on Form 10-K of Trilogy Metals Inc.; 

2.  Based  on  my  knowledge,  this  report  does  not  contain  any  untrue  statement  of  a  material  fact  or  omit  to  state  a  material  fact 
necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with 
respect to the period covered by this report; 

3.  Based  on  my  knowledge,  the  financial  statements,  and  other  financial  information  included  in  this  report,  fairly  present  in  all 
material respects the financial condition, results of operations and cash flows of the registrant as of, and for, the periods presented in 
this report; 

4. The registrant’s other certifying officer(s) and I are responsible for establishing and maintaining disclosure controls and procedures 
(as defined in Exchange Act Rules 13a-15(e) and 15d-15(e)) and internal control over financial reporting (as defined in Exchange Act 
Rules 13a-15(f) and 15d-15(f)) for the registrant and have: 

(a) Designed such disclosure  controls and procedures, or caused such disclosure controls and procedures to be designed 
under our supervision, to ensure that material information relating to the registrant, including its consolidated subsidiaries, is made 
known to us by others within those entities, particularly during the period in which this report is being prepared; 

(b)  Designed  such  internal  control  over  financial  reporting,  or  caused such  internal  control  over  financial  reporting  to  be 
designed under our supervision, to provide reasonable assurance regarding the reliability of financial reporting and  the preparation 
of financial statements for external purposes in accordance with generally accepted accounting principles; 

(c)  Evaluated  the  effectiveness  of  the  registrant’s  disclosure  controls  and  procedures  and  presented  in  this  report  our 
conclusions about the effectiveness of the disclosure controls and procedures, as of the end of the period covered by this report based 
on such evaluation; and 

(d) Disclosed in this report any change in the registrant's internal control over financial reporting that  occurred during the 
registrant's most recent fiscal quarter (the registrant's fourth fiscal quarter in the case of an annual report) that has materially affected, 
or is reasonably likely to materially affect, the registrant's internal control over financial reporting; and 

5. The registrant’s other certifying officer(s) and I have disclosed, based on our most recent evaluation of internal control over financial 
reporting,  to  the  registrant’s  auditors  and  the  audit  committee  of  the  registrant’s  board  of  directors  (or  persons  performing  the 
equivalent functions): 

(a) All significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting 
which are reasonably likely to adversely affect the registrant’s ability to record, process, summarize and report financial information; 
and 

(b) Any fraud, whether or not material, that involves management or other employees who have a significant role in the 

registrant’s internal control over financial reporting. 

Date: February 14, 2023 

By: 

/s/ Elaine Sanders 
Elaine Sanders 
Chief Financial Officer 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
  
 
Exhibit 32.1 

CERTIFICATION PURSUANT TO 

18 U.S.C. §1350, 

AS ADOPTED PURSUANT TO 

SECTION 906 OF THE SARBANES-OXLEY ACT OF 2002 

In connection with the Annual Report of Trilogy Metals Inc. (the “Company”) on Form 10-K for the year ended November 30, 2022, as 
filed with the Securities and Exchange Commission on the date hereof (the “Report”), I, Tony Giardini, Chief Executive Officer of the 
Company, certify that: 

1. The Report fully complies with the requirements of Section 13(a) or 15(d) of the Securities Exchange Act of 1934; and 

2.  The  information  contained  in  the  Report  fairly  presents,  in  all  material  respects,  the  financial  condition  and  results  of 

operations of the Company. 

Date: February 14, 2023 

By: 

/s/ Tony Giardini 
Tony Giardini 
Chief Executive Officer 

 
 
 
 
 
 
 
 
 
 
 
    
    
 
 
 
Exhibit 32.2 

CERTIFICATION PURSUANT TO 

18 U.S.C. §1350, 

AS ADOPTED PURSUANT TO 

SECTION 906 OF THE SARBANES-OXLEY ACT OF 2002 

In connection with the Annual Report of Trilogy Metals Inc. (the “Company”) on Form 10-K for the year ended November 30, 2022, as 
filed with the Securities and Exchange Commission on the date hereof (the “Report”), I, Elaine Sanders, Chief Financial Officer of the 
Company, certify that: 

1. The Report fully complies with the requirements of Section 13(a) or 15(d) of the Securities Exchange Act of 1934; and 

2.  The  information  contained  in  the  Report  fairly  presents,  in  all  material  respects,  the  financial  condition  and  results  of 

operations of the Company. 

Date: February 14, 2023 

By: 

/s/ Elaine Sanders 
Elaine Sanders 
Chief Financial Officer