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2021 Sustainability Report2021 Sustainability Reporting Data Sheet

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

2020 Sustainability Reporting Data Sheet

2020 Sustainability Report2020 Sustainability Reporting Data Sheet

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

2020 Sustainability Reporting Data Sheet

All reporting data listed below is based on NOVAGOLD’s 2021 fiscal year.

2021 Sustainability Summary

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

2021 ENVIRONMENTAL PERFORMANCE

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

Production Statistics
  Donlin Gold LLC NOVAGOLD
Item Value Comments Value Comments
Ounces of Gold Produced (Poured Ounces) 0 Not applicable - All of these are not applicable because the Donlin Gold project is not yet in operation. 0 Not applicable - NOVAGOLD has no operating projects.
Ore mined - Open Pit 0 Not Applicable 0 Not Applicable
Waste Rock Mined - Open Pit 0 Not Applicable 0 Not Applicable
Total Ore Processed 0 Not Applicable 0 Not Applicable
Cyanide Used 0 Not Applicable 0 Not Applicable
Waste Rock Backfilled - Surface 0 Not Applicable 0 Not Applicable
Tailings Produced 0 Not Applicable 0 Not Applicable
Waste That is Geochemically Reactive 0 Not Applicable 0 Not Applicable
Environmental Incidents
  Donlin Gold LLC NOVAGOLD
Item Value Comments Value Comments
Class I - High 0 Immediately reportable to government agencies or impacts beyond site boundary or to surface or ground water, or wildlife mortality of a protected species. 0 Immediately reportable to government agencies or impacts beyond site boundary or to surface or ground water, or wildlife mortality of a protected species.
Class II  - Medium 1 Reportable, but not immediately, to government agencies, within site boundary, no impacts to surface or ground water; or multiple wildlife mortalities of non-protected species. 0 Reportable, but not immediately, to government agencies, within site boundary, no impacts to surface or ground water; or multiple wildlife mortalities of non-protected species.
Class III - Low 1 Not reportable to government agencies, minimal impact within site boundary, and no more than one wildlife mortality. 0 Not reportable to government agencies, minimal impact within site boundary, and no more than one wildlife mortality.
How Many Environmental Incidents were Reported to the Authority? 1   0  
Non-Compliances
  Donlin Gold LLC NOVAGOLD
Item Value Comments Value Comments
Air 1 Non-compliance not related to any emissions but to a late report. 0  
Water 3 Administrative violations of permit conditions, not for any environmental effects. 0  
Waste 0   0  
Land 0   0  
Wildlife 0   0  
Other 0   0  
Environmental Related Fines
  Donlin Gold LLC NOVAGOLD
Item Value Comments Value Comments
Number of Fines Levied 0   0  
Value of Environmental- Related Fines 0   0  
Spills
  Donlin Gold LLC NOVAGOLD
Item Value Comments Value Comments
Number of Spills 1 None reportable to agencies, none to water, all less than 10 gallons to land. 0  
Volume of Oil Spills - Liters 3 None reportable to agencies, none to water, all less than 10 gallons to land. 0  
Volume of Fuel Spills - Liters 0   0  
Volume of Waste Spills - Liters 0   0  
Volume of Chemical Spills - Liters 0   0  
Volume of Other Spills - Liters 0   0  
Closure and Rehabilitation
  Donlin Gold LLC NOVAGOLD
Item Value Comments Value Comments
Total Land Disturbed and Not Yet Rehabilitated at Start of Reporting Period - Hectares 0.03 All land disturbance is associated with limited exploration level activities, no on-site mine waste or water management facilities. 0  
Total Amount of Land Newly Disturbed within Reporting Period - Hectares 6.15 All land disturbance is associated with limited exploration level activities, no on-site mine waste or water management facilities. 0  
Total Amount of Land Newly Rehabilitated within Reporting Period - Hectares 2.75 All land disturbance is associated with limited exploration level activities, no on-site mine waste or water management facilities. 0  
Total Rehab Planned for the Year (Hectares) 2.75 All land disturbance is associated with limited exploration level activities, no on-site mine waste or water management facilities. 0  
Waste
  Donlin Gold LLC NOVAGOLD
Item Value Comments Value Comments
Hazardous Waste Produced - Tonnes 0   0  
Non-Hazardous Waste Produced - Tonnes 27   0 With office shutdowns in 2021, non-hazardous waste generation was minimal in NOVAGOLD offices (<`50 pounds, rounded to zero tonnes)
Hazardous Waste Recycled - Tonnes 0   0  
Non-Hazardous Waste Recycled - Tonnes 0   0  
Total Reused - Tonnes 0   0  
Total Waste to Landfill - Tonnes 21   0  
Total Waste Incinerated - Tonnes 6   0  
Mercury Produced as a By-Product / Co-Product - Tonnes 0 No production or processing at Donlin Gold 0  
Emissions
  Donlin Gold LLC NOVAGOLD
Item Value Comments Value Comments
NOx - Stationary Sources - Tonnes 0 De minimis, small camp with no production at the Donlin Gold project 0  
Number of Regulatory Exceedances 0 De minimis, small camp with no production at the Donlin Gold project 0  
SOx - Stationary Sources - Tonnes 0 De minimis, small camp with no production at the Donlin Gold project 0  
Number of Regulatory Exceedances 0 De minimis, small camp with no production at the Donlin Gold project 0  
Particulate Matter - PM 10 - μg/m3 0 De minimis, small camp with no production at the Donlin Gold project 0  
Mercury Air Emissions - Tonnes 0 No production or processing at Donlin Gold 0  
Number of Regulatory Exceedances 0   0  
Other Air Emissions as Regulated (Tonnes) 0   0  
Water Use
  Donlin Gold LLC NOVAGOLD
Item Value Comments Value Comments
Surface Water - Cubic Meters 0   1,129 Includes Salt Lake City and Vancouver offices
Groundwater - Cubic Meters 1,684 All returned to ground after treatment 0  
Total Withdrawals - Cubic Meters 1,684   1,129  
Energy Inputs / GHG Emissions
  Donlin Gold LLC NOVAGOLD
Item Value Comments Value Comments
Electricity - from Outside Sources - KwH 0 All on-site power generation 54,270 All NOVAGOLD power from outside sources
Electricity - Self-Generated - KwH 814,023   0  
Diesel Used for Power Generation - Liters 137,305   0  
HFO Used for Power Generation - Liters 0   0  
Electricity Produced by Renewable Sources - KwH 0   0  
Natural Gas - MMBTU 0   0  
Diesel Used (Less Consumption for Power Generation) - Liters 246,515   0  
Propane Used - Liters 4,508   0  
Petrol / Gasoline Used - Liters 11,966   0  
Aviation Fuel Used 118,485   0  
Total Scope 1 GHG Emissions - Tonnes of CO2 1,084   0  
Scope 1 GHG Emissions from Diesel - Stationary 369   0  
Scope 1 GHG Emissions from Diesel - Mobile 661   0  
Total Scope 2 GHG Emissions 0   34  

2021 SOCIAL PERFORMANCE

The results below are reported separately for Donlin Gold LLC and NOVAGOLD, where applicable. Donlin Gold LLC information is reported on a 100 percent basis. For additional details on NOVAGOLD’s community and social development practices, please refer to NOVAGOLD’s most recent Form 10-K, Form 10-Q, and management information circular dated March 25, 2022, available at www.sec.gov, www.SEDAR.com or on  NOVAGOLD’s website at www.novagold.com/investors/invest/.

Additional details on social practices can also be found on the Donlin Gold LLC website: www.donlingold.com.

Employment
Item Donlin Gold NOVAGOLD Comments
Total OR
Low (if applicable) High (if applicable)
Male Employees 11 64 7 High ranges of Donlin Gold LLC employees in all rows reflects the seasonal nature of work at the project site.
Female Employees 10 17 6 In 2021, women comprised 46 percent (six of 13) of NOVAGOLD’s employees.
Male Contractors 1 1 0  
Female Contractors 0 0 0  
Local Employees 18 75 Not applicable “Local” is defined as Alaska
Regional Employees 2 30 Not applicable “Regional” is defined as Yukon-Kuskokwim region
Shareholder Employees 6 46 Not applicable “Shareholder” refers to having a relationship with Calista or TKC*
National Employees 21 81 13 “National” for Donlin Gold LLC refers to the USA; For NOVAGOLD, to USA and Canada
Foreign National Employees 0 0 0 All employees / contractors are U.S. or Canadian citizens
Local Senior Managers 6 6 Not applicable  
Regional Senior Managers 0 0 Not applicable  
National Senior Managers 6 8 Not applicable  
Foreign National Senior Managers 0 0 Not applicable All employees / contractors are U.S. or Canadian citizens
Number of Non-Management Employees who are Female 6 14 5 “Non-Management” for NOVAGOLD means non-executive
Number of Management-Level Employees who are Female 3 3 1 “Management” for NOVAGOLD means executive
Local Contractors 0 0 Not tracked  
Regional Contractors 0 0 Not tracked  
National Contractors 0 0 Not tracked  
Foreign National Contractors 0 0 Not applicable All employees / contractors are U.S. or Canadian citizens
Number of Suppliers with Clauses in Contracts Related to Local Employment 0 0 Not applicable  
* Calista Corporation (Calista), which owns the mineral resources at the Donlin Gold project, and the The Kuskokwim Corporation (TKC), which owns much of the surface land, are the Alaska Native Corporations that are our partners on the Donlin Gold project.
Turn Over
Item Donlin Gold NOVAGOLD Comments
Total OR
Low (if applicable) High (if applicable)
Total Number of Employees Who Left the Organization Voluntarily 65   0 Field season ended, Camp closure
Total Number of Employees Who Left the Organization Due to Dismissal 5   0  
Total Number of New Employee Hires 71   1  
Percentage of Open Positions Filled by Internal Candidates 0   0  
Labor Unions
Item Donlin Gold NOVAGOLD Comments
Total OR
Low (if applicable) High (if applicable)
Number of Employees Covered by Collective Bargaining Agreements 0   0 There are no unionized employees at either NOVAGOLD or Donlin Gold LLC.
Days Lost to Strike Action 0   0  
Training
Item Donlin Gold NOVAGOLD Comments
Total OR
Low (if applicable) High (if applicable)
Total Hours of Training for Employees 820   Not tracked    
Hours of Environmental Training for Employees and Contractors 353   Not tracked    
Hours of Health, Safety, and Emergency Response Training for Employees 388   Not tracked    
Hours of Health, Safety, and Emergency Response Training for Contractors 108   0    
Local Employment Plan
Item Donlin Gold NOVAGOLD Comments
Total OR
Low (if applicable) High (if applicable)
Is a Local Employment Plan In Place? Yes   Not applicable For Donlin Gold LLC, this relates to local Land Agreement/Shareholder hire agreements with Calista and TKC
Health and Safety
Item Donlin Gold NOVAGOLD Comments
Total OR
Low (if applicable) High (if applicable)
Near Misses 11   0  
First Aid / Minor Injury 4   0  
Medical - Days of Restriction 12   0  
Hours Worked - Employees and Contractors 171,292   Not tracked  
LTIFR 0   0 Lost Time Incident Frequency Rate is defined using the calculation of number of lost-time injuries per one million employee hours worked.
TRIFR 1.16   0 Total Recordable Incident Frequency Rate is defined as an incidence rate of lost-time injuries, fatalities, and medical incidents and is computed using the formula: (number of injuries and illnesses X 200,000) / employee hours worked = medical incidence rate. Note: ‘200,000’ represents the number of hours 100 employees work based on 40 hours per week, 50 weeks per year, and provides the standard base for calculating the incidence rate for an entire year.
Human Rights
Item Donlin Gold NOVAGOLD  
Total OR
Low (if applicable) High (if applicable)
Number of Employees Trained on Human Rights 71   13    
Number of Human Rights Grievances Escalated to Legal 0   0    
Business Ethics
Item Donlin Gold NOVAGOLD Comments
Total OR
Low (if applicable) High (if applicable)
Number of Reportable Code of Conduct Breaches Reported in the Fiscal Year 0   0  
Number of How Many Hours of Training on Anti-Corruption Received in the Fiscal Year 71   Not tracked  
Purchases
Item Donlin Gold NOVAGOLD Comments
Total OR
Low (if applicable) High (if applicable)
Purchases from Regional Suppliers - $USD $       821,071   Not tracked Good / Services from Y-K region
Purchases from Local Suppliers - $USD $    9,800,220   Not tracked Regional and Local (Alaska)
Purchases from National Suppliers - $USD $  16,931,030   Not tracked Regional, Local, and National (US)
Purchases from  International Suppliers - $USD $    7,221,612   Not tracked International only
Suppliers
Item Donlin Gold NOVAGOLD Comments
Total OR
Low (if applicable) High (if applicable)
Number of Regional Suppliers 490   Not tracked “Regional” is defined as Yukon-Kuskokwim region
Number of Local Suppliers 1,283   Not tracked “Local” is defined as Alaska
Number of National Suppliers 2,103   Not tracked Regional, Local, and National (US)
Number of International Suppliers 150   Not tracked International only
Local Procurement Plan in Place 0   Not applicable  
Grievances Received
Item Donlin Gold NOVAGOLD Comments
Total OR
Low (if applicable) High (if applicable)
Human Rights (Automatically Escalated) 0   0  
Unmet Obligation 0   0  
Resettlement / Relocation 0   0  
Land Compensation 0   0  
Land Encroachment 0   0  
Land Access 0   0  
Property Damage 0   0  
Road Quality 0   0  
Driving / Speeding 0   0  
Security Behavior 0   0  
Employee Behavior 0   0  
Contractor Behavior 0   0  
Contractor Payment Problems 0   0  
Local Procurement / Contracting 0   0  
Local Employment 0   0  
Spills 0   0  
Water 0   0  
Dust 0   0  
Emissions 0   0  
Noise / Light 0   0  
Vibrations 0   0  
Other 1   0  
Grievances Resolutions
Item Donlin Gold NOVAGOLD Comments
Total OR
Low (if applicable) High (if applicable)
Total Number of Grievances Remaining From the Previous Period 0   0  
Total Number of Grievances Received 1   0  
Community Engagement
Item Donlin Gold NOVAGOLD Comments
Total OR
Low (if applicable) High (if applicable)
Number of Engagements with Local Community Members 1,065   Not applicable For Donlin Gold LLC, this is tracked across more than 56 communities in the Yukon-Kuskokwim region.
Community Investment - Donlin Gold project only
Item Donlin Gold NOVAGOLD Comments
Total OR
Low (if applicable) High (if applicable)
Health - $USD $  153,699   Not applicable All NOVAGOLD investments are made through Donlin Gold LLC under the 50/50 partnership with Barrick. Therefore, NOVAGOLD provides 50 percent of the funds for the Donlin Gold LLC investments.
Education - $USD $  244,694   Not applicable  
Arts, Culture & Sports - $USD $  415,491   Not applicable  
Environment - $USD $  387,936   Not applicable  
Economic Development - $USD $    49,110   Not applicable  
Infrastructure - $USD $    42,000   Not applicable  
Water Infrastructure - $USD $              0   Not applicable  
Community Engagement - $USD $    20,697   Not applicable  
Other - $USD $      7,006   Not applicable  
Scholarships Provided - Quantity $  370,875   Not applicable  
Compensation Payments - $USD $              0   Not applicable  

2021 CORPORATE GOVERNANCE PERFORMANCE

For additional details on NOVAGOLD’s corporate governance practices, please see the most recent management information circular dated March 25, 2022 and posted to www.sec.gov, www.SEDAR.com or the NOVAGOLD website at www.novagold.com/investors/invest/.

General
Governance Item Value Additional Comments
Location of Corporate Office Vancouver, B.C., Canada; Salt Lake City, UT, USA  
Description of Services / Products Gold mine developer  
Location of Projects Not Applicable  
Status of Operations Not Applicable  
Ownership Publicly traded corporation under the laws of British Columbia, Canada, and trading on the NYSE American and TSX stock exchanges under the symbol NG.  
Does the Company have an Enterprise Level Environmental Policy? Yes. Applicable policy: https://www.novagold.com/_resources/governance/Environmental_Policy.pdf  
Global Compact Signatory No  
Memberships in Associations Alaska Miners Association, Council of Alaska Producers, National Mining Association, Resource Development Council (Alaska), and American Exploration and Mining Association (national)  
Statement from Senior Decision Maker Annual messages from Chairman and CEO are contained in the company’s annual report available on the website at https://www.novagold.com/investors/financials/  
Values, Principles, Standards, and Norms of Behavior See https://www.novagold.com/_resources/governance/Code-of-Business-Conduct-and-Ethics-2014-01-10.pdf and Code of Business Conduct  
Does the Company have a Publicly Disclosed Code of Conduct? Yes. Applicable policy: Code-of-Business-Conduct-and-Ethics-2014-01-10.pdf (novagold.com)  
Mechanisms for Advice and Concerns about Ethics Yes. Applicable policy: Code-of-Business-Conduct-and-Ethics-2014-01-10.pdf (novagold.com)  
Whistleblower Policy or Programs, Including Confidential Hotline and Stated Protection of Whistleblowers Yes. Applicable policy: Code-of-Business-Conduct-and-Ethics-2014-01-10.pdf (novagold.com)  
Process for Delegating Authority for Economic, Environmental, and Social Topics from the Highest Governance Body to Senior Executives and Other Employees Yes. Applicable policy: See pages 91-104 of Management Proxy Circular dated March 25, 2022  
Board Member or Board Committee Responsible for ESG Issues Applicable resources: https://www.novagold.com/_resources/governance/Corporate-Governance-and-Nominations-Charter-updated-Jan-27-2021.pdf and https://www.novagold.com/_resources/governance/EHSS-Technical-Committee-Charter-2016-11-18.pdf  
Composition of the Highest Governance Body and its Committees The Board of Directors is the highest governing body, consisting of 10 Directors, eight of whom are independent. There are five standing committees: Audit; Compensation; Environment, Health, Safety, Sustainability and Technical; Corporate Governance and Nominations; and Corporate Communications. https://www.novagold.com/company/directors/  
How many Women / What Proportion of Women are on the Board 3 of 10, or 30%  
How many Directors Serve on the Board 10  
Board Diversity and Board Independence Yes. See page 96-100 of Management Information Circular dated March 25, 2022 regarding Board independence and pages 100-103 regarding Board diversity  
Diversity Programs See pages 96-100 of Management Information Circular dated March 25, 2022  
Chair of the Highest Governance Body Thomas Kaplan, Chairman of the Board  
The Classification of the Board Chair Non-independent  
Does the Board have an Independent Lead Director? Yes. Anthony Walsh serves as the Board’s independent Lead Director  
Conflicts of Interest See pages 95-96 and 100-101 of Management Information Circular dated March 25, 2022 and the Code of Business Conduct and Ethics: https://www.novagold.com/_resources/governance/Code-of-Business-Conduct-and-Ethics-2014-01-10.pdf  
Role of the Highest Governance Body in Setting Purpose, Values, and Strategy See pages 91-104 of the Management Information Circular dated March 25, 2022  
Collective Knowledge of Highest Governance Body Board of Directors is highest governance body; see biographies of Directors at https://www.novagold.com/company/directors/ and additional Director background in the Management Information Circular dated March 25, 2022  
Evaluation of the Highest Governance Body’s Performance See pages 103 of the Management Information Circular dated March 25, 2022  
Remuneration Policies See Management Information Circular dated March 25, 2022  
Responsibility for Board and Executive Compensation See pages 29-59 of Management Information Circular dated March 25, 2022 and the Code of Business Conduct and Ethics: https://www.novagold.com/_resources/governance/Code-of-Business-Conduct-and-Ethics-2014-01-10.pdf  
Process for Determining Remuneration See Compensation Discussion and Analysis and Non-Executive Director Compensation in the Management Information Circular dated March 25, 2022  
Has the Company Adopted an Advisory Executive Compensation “Say on Pay” vote? Yes, vote held annually In 2021 shareholders cast 96.5% votes in favor of “Say on Pay”
Approach to Shareholder Engagement Maintaining an active shareholder engagement program continues to be a high priority for the Company and is an integral part of our corporate governance practices. The Board Chair, CEO, and Vice President of Corporate Communications meet regularly with large shareholders, and the Company’s Corporate Communications team is very responsive to shareholder inquiries regardless of ownership level. In 2021, NOVAGOLD placed calls to or met in person with all of its shareholders owning 40,000 shares or more; in other words, NOVAGOLD contacted or attempted to contact its owners holding approximately 92% of the Company’s issued and outstanding Common Shares entitled to vote at NOVAGOLD’s 2021 annual meeting of shareholders. We plan to continue to regularly engage with our shareholders.  
Date of Most Recent Annual Financial Report Annual Report on Form 10-K filed January 26, 2022  
Financial Reporting Cycle 2021 annual financial results reported January 2022. Q1 2022 financial report on Form 10-Q filed April 5, 2022; additional Form 10-Q filings planned in June 2022 and October 2022.  
Sustainability Reporting Cycle Sustainability Report issued annually  
Contact Point for Questions Regarding ESG Disclosure Vice President, Corporate Communications or Manager, Investor Relations: info@novagold.com or Telephone: 604-669-6227; Toll-free: 1-866-669-6227  
Human Rights
Governance Item Value Additional Comments
Human Rights Policy and Scope See https://www.novagold.com/_resources/governance/Human-Rights-Policy.pdf  
Does the Company’s Human Rights or Other Formal Policy Cover Community Consultations and Indigenous Rights? Yes  
Number of Grievances about Human Rights Filed, Addressed, and Resolved through Formal Grievance Mechanisms 0  
Incidents of Discrimination and Corrective Actions Taken 0  
Anti-Discrimination Policy See page 102 in the Management Information Circular dated March 25, 2022  
Operations and Suppliers at Significant Risk for Incidents of Child Labor No. All operations and suppliers exist under U.S. or Canadian regulations and labor standards  
Does the Company’s Code of Vendor Conduct Address Child Labor? No. We do not have a Code of Vendor Conduct; see Human Rights Policy  
Operations and Suppliers at Significant Risk for Incidents of Forced or Compulsory Labor No. All operations and suppliers exist under U.S. or Canadian regulations and standards of practice  
Does the Company’s Code of Vendor Conduct Address Forced Labor? No. We do not have a Code of Vendor Conduct; see Human Rights Policy  
Incidents of Violations Involving Rights of Indigenous Peoples 0  
Operations that have Been Subject to Human Rights Reviews or Impact Assessments 0 At Donlin Gold LLC, 85 employees have been trained in human rights. No grievances at either NOVAGOLD or Donlin Gold LLC were escalated to legal in 2021.
Employee Training on Human Rights Policies and Procedures All employees affirm their commitment to the Code of Business Conduct and Ethics annually  
Anti-Bribery & Anti-Corruption
Governance Item Value Additional Comments
Anti-Bribery & Anti-Corruption Policy https://www.novagold.com/_resources/governance/Anti-Corruption-Anti-Bribery-Anti-Fraud-Policy-2020-03-05.pdf  
Highest Level of Executive Oversight for the Company’s Anti-Bribery or Anti-Corruption Program Company Ethics Officer (Vice President & CFO)  
Number of Grievances about Anti-Corruption and Anti-Bribery, Addressed and Resolved Through Formal Grievance Mechanisms 0  
Operations Assessed for Risks Related to Corruption Not Applicable  
Does the Company Provide Anti-Corruption Training to all Employees, Including Management? All employees affirm their commitment to the Code of Business Conduct and Ethics annually  
Confirmed Incidents of Corruption and Actions Taken 0  
Payments to Governments NG_ESTMA-Report-FY-2021.pdf (novagold.com)  


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

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