NOVAGOLD: Reporting

2022 Sustainability Reporting Data Sheet

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

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

2021 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

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.

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

2022 ENVIRONMENTAL PERFORMANCE

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

Production Statistics

	Donlin Gold LLC		NOVAGOLD
Item	Value	Comments	Value	Comments
Ounces of Gold Produced (Poured Ounces)	0	Not applicable - All of these are not applicable because the Donlin Gold project is not yet in operation.	0	Not applicable - NOVAGOLD has no operating projects.
Ore mined - Open Pit	0	Not Applicable	0	Not Applicable
Waste Rock Mined - Open Pit	0	Not Applicable	0	Not Applicable
Total Ore Processed	0	Not Applicable	0	Not Applicable
Cyanide Used	0	Not Applicable	0	Not Applicable
Waste Rock Backfilled - Surface	0	Not Applicable	0	Not Applicable
Tailings Produced	0	Not Applicable	0	Not Applicable
Waste That is Geochemically Reactive	0	Not Applicable	0	Not Applicable

Environmental Incidents

	Donlin Gold LLC		NOVAGOLD
Item	Value	Comments	Value	Comments
Class I - High	0	Immediately reportable to government agencies or impacts beyond site boundary or to surface or ground water, or wildlife mortality of a protected species.	0	Immediately reportable to government agencies or impacts beyond site boundary or to surface or ground water, or wildlife mortality of a protected species.
Class II - Medium	0	Reportable within 48 hours to government agencies, within site boundary, no impacts to surface or ground water; or multiple wildlife mortalities of non-protected species.	0	Reportable within 48 hours to government agencies, within site boundary, no impacts to surface or ground water; or multiple wildlife mortalities of non-protected species.
Class III - Low	4	Reportable monthly, but not immediately, to government agencies, minimal impact within site boundary, and no more than one wildlife mortality.	0	Reportable monthly, but not immediately, to government agencies, minimal impact within site boundary, and no more than one wildlife mortality.
How Many Environmental Incidents were Reported to the Authority?	4		0

Non-Compliances

	Donlin Gold LLC		NOVAGOLD
Item	Value	Comments	Value	Comments
Air	0		0
Water	0		0
Waste	0		0
Land	0		0
Wildlife	0		0
Other	0		0

Environmental Related Fines

	Donlin Gold LLC		NOVAGOLD
Item	Value	Comments	Value	Comments
Number of Fines Levied	0		0
Value of Environmental- Related Fines	0		0

Spills

	Donlin Gold LLC		NOVAGOLD
Item	Value	Comments	Value	Comments
Number of Spills	4	None immediately reportable to agencies, none to water, all less than 10 gallons to land.	0
Volume of Oil Spills - Liters	5.7	None immediately reportable to agencies, none to water, all less than 10 gallons to land.	0
Volume of Fuel Spills - Liters	11.4	None immediately reportable to agencies, none to water, all less than 10 gallons to land.	0
Volume of Waste Spills - Liters	0		0
Volume of Chemical Spills - Liters	9.5	None to water, all less than 10 gallons to land.	0
Volume of Other Spills - Liters	0		0

Closure and Rehabilitation

	Donlin Gold LLC		NOVAGOLD
Item	Value	Comments	Value	Comments
Total Land Disturbed and Not Yet Rehabilitated at Start of Reporting Period - Hectares	8.7	All land disturbance is associated with limited exploration level activities, no on-site mine waste or water management facilities.	0
Total Amount of Land Newly Disturbed within Reporting Period - Hectares	15.7	All land disturbance is associated with limited exploration level activities, no on-site mine waste or water management facilities.	0
Total Amount of Land Newly Rehabilitated within Reporting Period - Hectares	8.2	All land disturbance is associated with limited exploration level activities, no on-site mine waste or water management facilities.	0
Total Rehab Planned for the Year (Hectares)	8.2	All land disturbance is associated with limited exploration level activities, no on-site mine waste or water management facilities.	0

Waste

	Donlin Gold LLC		NOVAGOLD
Item	Value	Comments	Value	Comments
Hazardous Waste Produced - Tonnes	0.23		0
Non-Hazardous Waste Produced - Tonnes	576		0
Hazardous Waste Recycled - Tonnes	0		0
Non-Hazardous Waste Recycled - Tonnes	0.74		0
Total Reused - Tonnes	0.74		0
Total Waste to Landfill - Tonnes	559		0
Total Waste Incinerated - Tonnes	64		0
Mercury Produced as a By-Product / Co-Product - Tonnes	0	No production or processing at Donlin Gold	0

Emissions

	Donlin Gold LLC		NOVAGOLD
Item	Value	Comments	Value	Comments
NOx - Stationary Sources - Tonnes	0	De minimis, small camp with no production at the Donlin Gold project	0
Number of Regulatory Exceedances	0	De minimis, small camp with no production at the Donlin Gold project	0
SOx - Stationary Sources - Tonnes	0	De minimis, small camp with no production at the Donlin Gold project	0
Number of Regulatory Exceedances	0	De minimis, small camp with no production at the Donlin Gold project	0
Particulate Matter - PM 10 - μg/m3	0	De minimis, small camp with no production at the Donlin Gold project	0
Mercury Air Emissions - Tonnes	0	No production or processing at Donlin Gold	0
Number of Regulatory Exceedances	0		0
Other Air Emissions as Regulated (Tonnes)	0		0

Water Use

	Donlin Gold LLC		NOVAGOLD
Item	Value	Comments	Value	Comments
Surface Water - Cubic Meters	0		379	Includes Salt Lake City and Vancouver offices
Groundwater - Cubic Meters	2,080	All returned to ground after treatment	0
Total Withdrawals - Cubic Meters	2,080	All returned to ground after treatment	379

Biodiversity

Biodiversity policy

Biodiversity policy pdf

Climate Change

Climate Change Policy

Climate Change policy pdf

Energy Inputs / GHG Emissions

	Donlin Gold LLC		NOVAGOLD
Item	Value	Comments	Value	Comments
Electricity - from Outside Sources - KwH	0	All on-site power generation	54,270	All NOVAGOLD power from outside sources
Electricity - Self-Generated - KwH	1,198,433		0
Diesel Used for Power Generation - Liters	227,161		0
HFO Used for Power Generation - Liters	0		0
Electricity Produced by Renewable Sources - KwH	0		0
Natural Gas - MMBTU	0		0
Diesel Used (Less Consumption for Power Generation) - Liters	719,159		0
Propane Used - Liters	3,305		0
Petrol / Gasoline Used - Liters	24,594		0
Aviation Fuel Used	170,990		0
Total Scope 1 GHG Emissions - Tonnes of CO₂	2,633		0
Scope 1 GHG Emissions from Diesel - Stationary	610		0
Scope 1 GHG Emissions from Diesel - Mobile	1928		0
Total Scope 2 GHG Emissions	0		34

2022 SOCIAL PERFORMANCE

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

Employment

Item	Donlin Gold		NOVAGOLD	Comments
	Total OR
	Low (if applicable)	High (if applicable)
Male Employees	31	90	7	High ranges of Donlin Gold LLC employees in all rows reflect the seasonal nature of work at the project site.
Female Employees	13	24	6	In 2021, women comprised 46 percent (six of 13) of NOVAGOLD’s employees.
Male Contractors	2	2	0
Female Contractors	0	0	0
Local Employees	34	94	Not applicable	“Local” is defined as Alaska
Regional Employees	17	53	Not applicable	“Regional” is defined as Yukon-Kuskokwim region
Shareholder Employees	16	72	Not applicable	“Shareholder” refers to having a relationship with Calista or TKC*
National Employees	45	112	13	“National” for Donlin Gold LLC refers to the USA; For NOVAGOLD, to USA and Canada
Foreign National Employees	0	0	0
Local Senior Managers	5	6	Not applicable
Regional Senior Managers	0	0	Not applicable
National Senior Managers	7	8	Not applicable
Foreign National Senior Managers	0	0	Not applicable	All employees / contractors are U.S. or Canadian citizens
Number of Non-Management Employees who are Female	10	22	5	“Non-Management” for NOVAGOLD means non-executive
Number of Management-Level Employees who are Female	2	3	1	“Management” for NOVAGOLD means executive
Local Contractors	2	2
Regional Contractors	0	0	Not tracked
National Contractors	0	0	Not tracked
Foreign National Contractors	0	0	Not applicable	All employees / contractors are U.S. or Canadian citizens
Number of Suppliers with Clauses in Contracts Related to Local Employment	0	0	Not applicable
* Calista Corporation (Calista), which owns the mineral resources at the Donlin Gold project, and the The Kuskokwim Corporation (TKC), which owns much of the surface land, are the Alaska Native Corporations that are our partners on the Donlin Gold project.

Turn Over

Item	Donlin Gold		NOVAGOLD	Comments
	Total OR
	Low (if applicable)	High (if applicable)
Total Number of Employees Who Left the Organization Voluntarily	22		2	Donlin Gold field season ended, Camp closure
Total Number of Employees Who Left the Organization Due to Dismissal	6		0
Total Number of New Employee Hires	71		1
Percentage of Open Positions Filled by Internal Candidates	0		0

Labor Unions

Item	Donlin Gold		NOVAGOLD	Comments
	Total OR
	Low (if applicable)	High (if applicable)
Number of Employees Covered by Collective Bargaining Agreements	0		0	There are no unionized employees at either NOVAGOLD or Donlin Gold LLC.
Days Lost to Strike Action	0		0

Training

Item	Donlin Gold
	Total OR
	Low (if applicable)	High (if applicable)
Total Hours of Training for Employees	1,082
Hours of Environmental Training for Employees and Contractors	314
Hours of Health, Safety, and Emergency Response Training for Employees	95
Hours of Health, Safety, and Emergency Response Training for Contractors	88

Local Employment Plan

Item	Donlin Gold		NOVAGOLD	Comments
	Total OR
	Low (if applicable)	High (if applicable)
Is a Local Employment Plan In Place?	Yes		Not applicable	For Donlin Gold LLC, this relates to local Land Agreement/Shareholder hire agreements with Calista and TKC

Health and Safety

Item	Donlin Gold		NOVAGOLD	Comments
	Total OR
	Low (if applicable)	High (if applicable)
Near Misses	7		0
First Aid / Minor Injury	5		0
Medical - Days of Restriction	10		0
Hours Worked - Employees and Contractors	274,968		0
LTIFR	0		0	Lost Time Incident Frequency Rate is defined using the calculation of number of lost-time injuries per one million employee hours worked.
TRIFR	1.42		0	Total Recordable Incident Frequency Rate is defined as an incidence rate of lost-time injuries, fatalities, and medical incidents and is computed using the formula: (number of injuries and illnesses X 200,000) / employee hours worked = medical incidence rate. Note: ‘200,000’ represents the number of hours 100 employees work based on 40 hours per week, 50 weeks per year, and provides the standard base for calculating the incidence rate for an entire year.

Human Rights

Item	Donlin Gold		NOVAGOLD
	Total OR
	Low (if applicable)	High (if applicable)
Number of Employees Trained on Human Rights	75		13
Number of Human Rights Grievances Escalated to Legal	0		0

Business Ethics

Item	Donlin Gold		NOVAGOLD
	Total OR
	Low (if applicable)	High (if applicable)
Number of Reportable Code of Conduct Breaches Reported in the Fiscal Year	0		0
Number of How Many Hours of Training on Anti-Corruption Received in the Fiscal Year	75		Not tracked

Purchases

Item	Donlin Gold		NOVAGOLD	Comments
	Total OR
	Low (if applicable)	High (if applicable)
Purchases from Regional Suppliers - $USD	$ 2,099,139		Not tracked	Goods / Services from Y-K region
Purchases from Local Suppliers - $USD	$ 13,058,945		Not tracked	Regional and Local (Alaska)
Purchases from National Suppliers - $USD	$ 9,538,019		Not tracked	Regional, Local, and National (US)
Purchases from International Suppliers - $USD	$ 17,526,163		Not tracked	International only

Suppliers

Item	Donlin Gold		NOVAGOLD	Comments
	Total OR
	Low (if applicable)	High (if applicable)
Number of Regional Suppliers	540		Not tracked	“Regional” is defined as Yukon-Kuskokwim region
Number of Local Suppliers	838		Not tracked	“Local” is defined as Alaska
Number of National Suppliers	488		Not tracked	Regional, Local, and National (US)
Number of International Suppliers	187		Not tracked	International only
Local Procurement Plan in Place	0		Not applicable

Grievances Received

Item	Donlin Gold		NOVAGOLD
	Total OR
	Low (if applicable)	High (if applicable)
Human Rights (Automatically Escalated)	0		0
Unmet Obligation	0		0
Resettlement / Relocation	0		0
Land Compensation	0		0
Land Encroachment	0		0
Land Access	0		0
Property Damage	0		0
Road Quality	0		0
Driving / Speeding	0		0
Security Behavior	0		0
Employee Behavior	0		0
Contractor Behavior	0		0
Contractor Payment Problems	0		0
Local Procurement / Contracting	0		0
Local Employment	0		0
Spills	0		0
Water	0		0
Dust	0		0
Emissions	0		0
Noise / Light	0		0
Vibrations	0		0
Other	0		0

Grievances Resolutions

Item	Donlin Gold		NOVAGOLD
	Total OR
	Low (if applicable)	High (if applicable)
Total Number of Grievances Remaining From the Previous Period	0		0
Total Number of Grievances Received	0		0

Community Engagement

Item	Donlin Gold		NOVAGOLD	Comments
	Total OR
	Low (if applicable)	High (if applicable)
Number of Engagements with Local Community Members	6,370		Not applicable	For Donlin Gold LLC, this is tracked across more than 56 communities in the Yukon-Kuskokwim region.

Community Investment - Donlin Gold project only

Item	Donlin Gold		NOVAGOLD	Comments
	Total OR
	Low (if applicable)	High (if applicable)
Health - $USD	$ 464,150		Not applicable	All NOVAGOLD investments are made through Donlin Gold LLC under the 50/50 partnership with Barrick. Therefore, NOVAGOLD provides 50 percent of the funds for the Donlin Gold LLC investments.
Education - $USD	$ 299,650		Not applicable
Arts, Culture & Sports - $USD	$ 710,000		Not applicable
Environment - $USD	$ 51,799		Not applicable
Economic Development - $USD	$ 33,176		Not applicable
Infrastructure - $USD	$ 30,000		Not applicable
Water Infrastructure - $USD	$ 0		Not applicable
Community Engagement - $USD	$ 0		Not applicable
Other - $USD	$ 0		Not applicable
Scholarships Provided - Quantity	$ 75,000		$5,000
Compensation Payments - $USD	$ 0		Not applicable

2022 CORPORATE GOVERNANCE PERFORMANCE

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

General

Governance Item	Value	Additional Comments
Location of Corporate Office	Vancouver, B.C., Canada; Salt Lake City, UT, USA
Description of Services / Products	Gold mine developer
Location of Projects	Alaska
Status of Operations	Development stage
Ownership	Publicly traded corporation under the laws of British Columbia, Canada, and trading on the NYSE American and TSX stock exchanges under the symbol NG.
Does the Company have an Enterprise Level Environmental Policy?	Yes. Applicable policy: https://www.novagold.com/_resources/governance/Environmental_Policy.pdf
Global Compact Signatory	No
Memberships in Associations	Alaska Miners Association, Council of Alaska Producers, National Mining Association, Resource Development Council (Alaska), and American Exploration and Mining Association (national)
Statement from Senior Decision Maker	Annual messages from Chairman and CEO are contained in the company’s annual report available on the website at https://www.novagold.com/investors/financials/
Values, Principles, Standards, and Norms of Behavior	See https://www.novagold.com/_resources/governance/Code-of-Business-Conduct-and-Ethics-2014-01-10.pdf and Code of Business Conduct
Does the Company have a Publicly Disclosed Code of Conduct?	Yes. Applicable policy: Code-of-Business-Conduct-and-Ethics-2014-01-10.pdf (novagold.com)
Mechanisms for Advice and Concerns about Ethics	Yes. Applicable policy: Code-of-Business-Conduct-and-Ethics-2014-01-10.pdf (novagold.com)
Whistleblower Policy or Programs, Including Confidential Hotline and Stated Protection of Whistleblowers	Yes. Applicable policy: Code-of-Business-Conduct-and-Ethics-2014-01-10.pdf (novagold.com)
Process for Delegating Authority for Economic, Environmental, and Social Topics from the Highest Governance Body to Senior Executives and Other Employees	Yes. Applicable policy: See pages 95-111 of Management Proxy Circular dated March 24, 2023
Board Member or Board Committee Responsible for ESG Issues	Applicable resources: https://www.novagold.com/_resources/governance/Corporate-Governance-and-Nominations-Charter-updated-Jan-27-2021.pdf and https://www.novagold.com/_resources/governance/EHSS-Technical-Committee-Charter-2016-11-18.pdf and Sustainability Committee Charter https://www.novagold.com/_resources/governance/Sustainability-Committee-Charter-20221205.pdf
Composition of the Highest Governance Body and its Committees	The Board of Directors is the highest governing body, consisting of 11 Directors, eight of whom are independent. There are five standing committees: Audit; Compensation; Engineering and Technical; Corporate Governance and Nominations; and Sustainability. Read more here.
How many Women / What Proportion of Women are on the Board	3 of 10, or 30%
How many Directors Serve on the Board	11 seats, 10 current directors and one vacancy
Board Diversity and Board Independence	Yes. See page 95-98 of Management Information Circular dated March 24, 2023 regarding Board independence and pages 102-104 regarding Board diversity
Diversity Programs	See pages 102-106 of Management Information Circular dated March 24, 2023
Chair of the Highest Governance Body	Thomas Kaplan, Chairman of the Board
The Classification of the Board Chair	Non-independent
Does the Board have an Independent Lead Director?	Yes. Anthony Walsh serves as the Board’s independent Lead Director
Conflicts of Interest	See pages 95-101 of Management Information Circular dated March 24, 2023 and the Code of Business Conduct and Ethics: https://www.novagold.com/_resources/governance/Code-of-Business-Conduct-and-Ethics-2014-01-10.pdf
Role of the Highest Governance Body in Setting Purpose, Values, and Strategy	See pages 95-111 of the Management Information Circular dated March 24, 2023
Collective Knowledge of Highest Governance Body	Board of Directors is highest governance body; see biographies of Directors at https://www.novagold.com/company/directors/ and additional Director background in the Management Information Circular dated March 24, 2023
Evaluation of the Highest Governance Body’s Performance	See pages 110 of the Management Information Circular dated March 24, 2023
Remuneration Policies	See Management Information Circular dated March 24, 2023
Responsibility for Board and Executive Compensation	See pages 45-92 of Management Information Circular dated March 24, 2023 and the Compensation Committee Charter and the Board Charter. https://www.novagold.com/company/governance/
Process for Determining Remuneration	See See Compensation Discussion and Analysis and Non-Executive Director Compensation on pages 45-92 in the Management Information Circular dated March 24, 2023
Has the Company Adopted an Advisory Executive Compensation “Say on Pay” vote?	Yes, vote held annually	In 2022 shareholders cast 95.3% votes in favor of “Say on Pay”
Approach to Shareholder Engagement	Maintaining an active shareholder engagement program is a high priority for the Company and is an integral part of our corporate governance practices. The Board Chair, CEO, and Vice President of Corporate Communications meet regularly with large shareholders, and the Company’s Corporate Communications team is very responsive to shareholder inquiries regardless of ownership level. In 2022, NOVAGOLD placed calls to or met in person with all of its shareholders owning 40,000 shares or more; in other words, NOVAGOLD contracted or attempted to contact its owners holding approximately 86% of the Company’s issued and outstanding Common Shares entitled to vote at NOVAGOLD’s 2022 annual meeting of shareholders. We plan to continue to regularly engage with our shareholders.
Date of Most Recent Annual Financial Report	Annual Report on Form 10-K filed January 25, 2023
Financial Reporting Cycle	2022 annual financial results reported January 25, 2023. Q1 2023 financial report on Form 10-Q filed April 4, 2023; additional Form 10-Q filings planned in June 2023 and October 2023.
Sustainability Reporting Cycle	Sustainability Report issued annually
Contact Point for Questions Regarding ESG Disclosure	Vice President, Corporate Communications or Manager, Investor Relations: info@novagold.com or Telephone: 604-669-6227; Toll-free: 1-866-669-6227

Human Rights

Governance Item	Value	Additional Comments
Human Rights Policy and Scope	See https://www.novagold.com/_resources/governance/Human-Rights-Policy.pdf
Does the Company’s Human Rights or Other Formal Policy Cover Community Consultations and Indigenous Rights?	Yes
Number of Grievances about Human Rights Filed, Addressed, and Resolved through Formal Grievance Mechanisms	0
Incidents of Discrimination and Corrective Actions Taken	0
Anti-Discrimination Policy	See page 100-106 in the Management Information Circular dated March 24, 2023
Operations and Suppliers at Significant Risk for Incidents of Child Labor	No. All operations and suppliers are located in and operated under U.S. or Canadian regulations and labor standards
Does the Company’s Code of Vendor Conduct Address Child Labor?	No. We do not have a Code of Vendor Conduct; see Human Rights Policy
Operations and Suppliers at Significant Risk for Incidents of Forced or Compulsory Labor	No. All operations and suppliers are located in and operated under U.S. or Canadian regulations and labor standards
Does the Company’s Code of Vendor Conduct Address Forced Labor?	No. We do not have a Code of Vendor Conduct; see Human Rights Policy
Incidents of Violations Involving Rights of Indigenous Peoples	0
Operations that have Been Subject to Human Rights Reviews or Impact Assessments	0	At Donlin Gold LLC, 85 employees have been trained in human rights. No grievances at either NOVAGOLD or Donlin Gold LLC were escalated to legal in 2022.
Employee Training on Human Rights Policies and Procedures	All NOVAGOLD employees affirm their commitment to the Code of Business Conduct and Ethics annually

Anti-Bribery & Anti-Corruption

Governance Item	Value	Additional Comments
Anti-Bribery & Anti-Corruption Policy	https://www.novagold.com/_resources/governance/Anti-Corruption-Anti-Bribery-Anti-Fraud-Policy-2020-03-05.pdf
Highest Level of Executive Oversight for the Company’s Anti-Bribery or Anti-Corruption Program	Company Ethics Officer (Vice President & CFO)
Number of Grievances about Anti-Corruption and Anti-Bribery, Addressed and Resolved Through Formal Grievance Mechanisms	0
Operations Assessed for Risks Related to Corruption	Not Applicable
Does the Company Provide Anti-Corruption Training to all Employees, Including Management?	All NOVAGOLD employees affirm their commitment to the Code of Business Conduct and Ethics annually
Confirmed Incidents of Corruption and Actions Taken	0
Payments to Governments	https://novagold.com/_resources/financials/NG_ESTMA-Report-FY-2022.pdf (novagold.com)

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

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