ESG Report 2024
Governance Approach
STRUCTURE
The Board of Directors provides oversight of the Alamos senior management team and their application of the Company’s systems of corporate governance, financial reporting and risk management. Together, they are responsible for adequate and fair disclosure to shareholders and the Company’s ethical and legal conduct.
For a detailed overview of our governance structure, including profiles of our Board of Directors and a list of all Board sub-committees with their mandates, visit the About section of the Alamos website. To learn more about the nomination and selection process for Board and sub-committee members – including the specific criteria considered, such as diversity, independence, competencies, and stakeholder perspectives – refer to our Management Information Circular.
Composition of Alamos’ Board of Directors1
Table 2.1
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| Gender and Age | Percentage |
|---|---|
| Male | 67% |
| Female | 33% |
| Under 30 Years Old | 0% |
| 30 – 50 Years Old | 0% |
| Over 50 Years Old | 100% |
| Belong to a Visible Minority Group | 0% |
The Technical and Sustainability (T&S) Committee of the Board oversees Alamos’ sustainability performance. While the Committee does not directly prepare the annual ESG Report, this responsibility lies with Alamos’ Sustainability team and senior management. As part of its mandate, the Committee reviews the Company’s values, strategies, policies, goals, and programs to ensure they prevent or minimise operational impacts on factors relevant to sustainability. It also assesses their effectiveness through an annual performance review. Additionally, the Public Affairs Committee reviews the measures and resources dedicated to fostering positive relationships with stakeholders affected by Alamos’ operations. For full details of the responsibilities of the T&S and Public Affairs Committees, refer to the Technical and Sustainability Committee Charter and Public Affairs Committee Charter.
The Vice President (VP) of Sustainability and External Affairs is the most senior executive responsible for sustainability matters. The VP is supported by the corporate Sustainability Department and site-based Environment, Community Relations, and Health and Safety teams. Reporting to the Chief Operating Officer (COO), the VP and COO meet with the T&S Committee at least twice a year to discuss sustainability management.
Sustainability performance is a factor in executive compensation. The Chair of the Board, the Chair of the Human Resources Committee, and Alamos management meet annually to review the Organisation’s performance for the year, by comparing year-end corporate metrics against a series of pre-determined, measurable, weighted targets. A portion of the Annual Incentive Bonus (for eligible executives and employees) is tied to the Company’s achievement of these targets. In 2024, 15% of the weighting was allocated to environmental, social and corporate governance (ESG) targets. Alamos’ success in achieving these targets is quantified in our Management Information Circular.
Continuous Improvement
Alamos is committed to continuous improvement at all levels, including the Board of Directors. Established in 2016, the Director Education Policy promotes ongoing learning by reimbursing expenses for Director courses and self-study. The Company also encourages and supports directors in attending conferences, seminars, and training programs relevant to their roles, including those focused on sustainability. Additionally, several board members hold the Institute of Corporate Directors’ ICD.D designation, which requires a minimum of 14 hours of continuing education annually.
In December 2024, a portion of the board participated in a cybersecurity training session led by a leading accounting firm. That same month, board members attended an ESG and climate-related disclosure education session, covering the Canadian Sustainability Disclosure Standards and the Consolidated Mining Standard Initiative.
To ensure accountability and effectiveness, the board conducts an annual evaluation of its performance, as well as that of its committees and individual directors. This process includes a detailed self-assessment survey, reviewing the board’s mandate, committee effectiveness, and individual director contributions. Additionally, each board member participates in a one-on-one interview with the chair, with the survey incorporating both self and peer reviews to provide a well-rounded assessment of board and committee performance.
The Board evaluates the effectiveness of itself, its committees, and individual Directors on an annual basis.
Business Ethics
OUR COMMITMENT
At Alamos, we are dedicated to responsible business conduct, upheld through our Corporate Policies and ongoing monitoring of performance. Compliance with our Code of Business Conduct and Ethics is mandatory for all directors, officers, employees, and consultants. The code establishes our commitment to:
- Honest and ethical conduct in all business dealings
- Transparent, accurate, and timely disclosure in public reports and communications
- Strict compliance with applicable laws, regulations, and stock exchange rules.
To ensure these commitments are met, the code emphasises individual due diligence and the precautionary principle, guiding decision-making that prioritizes integrity and accountability.
Our Human Rights Policy further reinforces our commitment to respecting and supporting human rights. This policy aligns with internationally recognized frameworks, including the International Bill of Human Rights and the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work.
CONFLICTS OF INTEREST
To maintain the highest standards of governance, the Board of Directors strives to remain free from actual, perceived or potential conflicts of interest wherever possible. Currently, no two board members serve together on the boards or board committees of other public companies, and apart from the CEO, no directors are involved in the day-to-day operations of Alamos.
Any activity that could create a conflict of interest is strictly prohibited, unless expressly approved by the board or the Audit Committee. Directors are required to disclose all actual or potential conflicts and must abstain from voting on any related matters. If a conflict arises, the director must also recuse themselves from discussions and decisions where their impartiality may be compromised.
Anti-Bribery & Corruption
Alamos maintains a zero-tolerance approach to bribery and corruption. All personnel and business partners – including employees, suppliers, contractors, and subcontractors – are expected to operate legally and ethically while adhering to the Alamos Anti-Bribery, Anti-Corruption and Anti-Competition Policy (ABCC Policy) and all applicable laws.
Alamos does not operate in any of the 20 lowest-ranked countries on Transparency International’s 2024 Corruption Perceptions Index. Our ABCC Policy reinforces our commitment to honest and ethical conduct and strict compliance with applicable laws and regulations. To support this, we have robust awareness and compliance education programs, a confidential internal reporting system, and investigative procedures to address potential violations.
We have processes in place to cultivate a Company-wide culture of awareness and compliance education.
Our ABCC Policy Has Been Communicated To…
Table 2.2
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| 100% of Board Members | 100% of Employees | 72% of Business Partners2 |
|---|---|---|
We also support the Extractive Industries Transparency Initiative (EITI) and have complied with Canada’s Extractive Sector Transparency Measures Act (ESTMA) since 2016, which aligns with EITI reporting standards. In accordance with ESTMA, we publicly disclose all payments of $100,000 or more made to governments in Canada and abroad related to mineral development. Alamos does not make contributions to political parties or politicians.
To proactively address corruption risks, 100% of our operating mines undergo an annual Fraud Risk Assessment as part of Alamos’ Internal Controls/SOX program. Led by the Executive team in collaboration with senior management at each site, this assessment covers corruption risks, financial reporting fraud, and theft of assets. Corruption risk at Alamos operations has been assessed as low, with strong internal mitigation controls in place. Our Risk Management Program is designed to ensure we meet strategic objectives while protecting our people, assets, stakeholders, reputation, and the environment. The program focuses on:
- Identifying and integrating business risks across functions (health, safety, security, environment, community relations, etc.),
- Reducing risk likelihood and consequences to acceptable levels, and
- Making informed decisions based on risk-tolerance.
In 2024, there were zero (0) confirmed instances of corruption at any Alamos site, and zero (0) public legal cases related to corruption involving the company or its employees.
Communicating Critical Concerns
Alamos strongly encourages the timely reporting of actual or suspected violations of our Code of Business Conduct and Ethics, associated policies, and applicable laws, rules, and regulations. To facilitate this, we maintain an accessible, independent whistleblower system that allows employees, contractors and directors to confidentially report concerns or complaints – securely and anonymously – through the NAVEX Global EthicsPoint platform.
All employees are informed of this system, with clear communication channels posted across all operations and offices. Additional details are outlined in our Code of Business Conduct and Ethics, available on our website.
Alamos is committed to addressing and remediating any potential negative impacts arising from violations – all violation reports are addressed and investigated immediately by members of the Board of Directors. The Chair of the Audit Committee or her designee holds the sole responsibility to judge whether there has been a violation of the Code and, if warranted, determines an appropriate response, including corrective action and preventative measures, involving the Chair of the Audit Committee or Chief Executive Officer when required.
The effectiveness of our whistleblower system is monitored by tracking case outcomes and investigation timelines. In 2024, whistleblower activity across our four operating mines is summarized in Table 2.3. Additionally, one report was received at the Toronto Head Office and communicated to the Board, however, it did not warrant an investigation. No reports were filed at any of Alamos’ non-operational locations.
2024 Whistleblower Activity
Table 2.3
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| Activity Data | Young-Davidson | Island Gold | Magino | Mulatos |
|---|---|---|---|---|
| Total Reports Received | 4 | 0 | 1 | 3 |
| Reports Received That Warrant Investigation | 1 | 0 | 1 | 3 |
| Reports Received, Investigated, and Closed in the Reporting year | 1 | 0 | 1 | 3 |
Performance
To assess the effectiveness of our governance approach, Alamos monitors compliance and business ethics performance with the same level of rigor and accountability as our environmental, social, and economic indicators. Our compliance procedures are reviewed annually by legal counsel and updated as necessary. Additionally, we conduct periodic reviews and testing of our standards, procedures, and codes to ensure continuous improvement.
At our Young-Davidson mine, two environmental non-compliances were settled in 2024. In October 2023 and January 2024, the mine’s final effluent exceeded provincial limits for the mortality of Daphnia Magna (water fleas), resulting in a cumulative penalty of $10,220. The issue has since been fully rectified.
No other fines or non-monetary sanctions were issued against any Alamos operation in 2024. Over the three years prior to 2024, Alamos received a total of three monetary sanctions, amounting to $14,192.
Alamos tracks compliance and business ethics performance with the same focus and rigour as our environmental, social, and economic indicators.
Our Policies
Alamos upholds high standards of corporate governance to ensure that our decision-making aligns with our values and commitment to sustainable development. Our policy commitments incorporate industry-leading practices and establish clear expectations for every employee, contractor and visitor at our sites. We also expect the principles outlined in our policies to be embraced by all business partners and stakeholders with whom we collaborate.
Each policy or standard is overseen by a designated member of the management team, ensuring that commitments are effectively integrated into organizational strategies and operational procedures. Our Sustainability Policy is approved at the highest level – by the Technical and Sustainability (T&S) Committee of the Board of Directors.
Given the diverse roles and skillsets across our operations, projects, and offices, we provide tailored training to ensure employees understand and implement policy commitments relevant to their responsibilities. All corporate policies are communicated to new employees upon joining Alamos and remain publicly available on our website for easy access by other relevant parties. Employees seeking guidance on policy implementation can consult their supervisor or the policy owner listed in the document.
Our corporate policies are accessible here or can be viewed directly via the links below:
Stakeholder Management
APPROACH TO STAKEHOLDER ENGAGEMENT
At Alamos, we are committed to the well-being of our company, our people, our stakeholders, and the communities where we operate. Our definition of stakeholders includes employees, contractors, governments, value chain partners, media, and communities of interest – all of whom we actively engage with. While each stakeholder group has a unique relationship with Alamos, we recognize the interconnections between them and are committed to an engagement approach that is both values-driven and tailored to specific situations.
Some stakeholder relationships are voluntary, such as those with our shareholders, industry associations, and business partners, while others are regulated, particularly those with government bodies and communities of interest. Additionally, some relationships form passively, without direct input from the Company – for example, coverage by media outlets, non-governmental organisations, or industry analysts. To ensure effective engagement, each stakeholder group is identified and managed through dedicated functions including Sustainability, External Affairs, Public Affairs, and Investor Relations.
At Alamos, stakeholder engagement is about more than communication – it is about building and maintaining positive, transparent, and collaborative relationships. This approach fosters meaningful dialogue that helps drive mutually beneficial outcomes for both Alamos and our stakeholders.
The purpose of stakeholder engagement is to establish and continuously nurture positive, collaborative, and transparent relationships.
Stakeholder Engagement
Table 2.4
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| Stakeholder | Engagement Mechanism | Key Topics Raised in 2024 | Relevant Sites |
|---|---|---|---|
| Employee Engagement Committees |
|
|
All |
| Labor Unions |
|
|
Mulatos |
| Suppliers |
|
|
All |
| Indigenous Peoples |
|
|
Young-Davidson Island Gold Magino Lynn Lake Toronto Head Office |
| Local Communities |
|
|
All |
|
Investors Shareholders Analysts |
|
|
Toronto Head Office |
| Media |
|
|
Toronto Head Office |
| Industry Associations |
|
|
All |
| Government and Regulators |
|
|
All |
MEMBERSHIP ASSOCIATIONS
Our involvement in regional and industry associations provides valuable opportunities to engage with stakeholders, contribute to industry advancements, and participate in public policy discussions.
Alamos is a proud member of several key organisations including the World Gold Council, the Prospectors & Developers Association of Canada, the Canadian Chamber of Commerce, the Conference Board of Canada, the Canadian Institute of Mining, the Canadian Chamber of Commerce in Mexico, the Mexican Chamber of Mines, the Mexican Mining Association, the Ontario Mining Association, the Ontario Chamber of Commerce, the Mining Association of Manitoba, and the Manitoba Chambers of Commerce.
DOWNSTREAM PARTNERS
In September 2023, the members of the World Gold Council – representing the majority of the global large-scale gold mining industry – announced a collective commitment to greater transparency across the gold supply chain. As part of this initiative, members pledged to publicly disclose the names and locations of their refining partners at least once per year. This effort aims to build trust and assurance among stakeholders – including users, investors, regulators, and supply chain partners – that gold is being mined and sourced responsibly.
At Alamos, we are proud to support this commitment. We work with the following downstream partners to refine the doré and gold-bearing material we produce:
Downstream Refineries
Table 2.5
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| INDICATOR | Royal Canadian Mint | SIPI Metals Corp. | MKS PAMP SA. |
|---|---|---|---|
| Location | Ottawa, Canada | Chicago, United States | PAMP Refinery, Castel San Pietro, Switzerland |
| Product Refined | Doré | Carbon & Other Materials | Doré |
| Portion of Alamos’ Total 2024 Gold Ounces Refined | 63.7% | 0.3% | 36.0% |
References
- At December 31st, 2024 ↩
- Business Partners include suppliers and contractors who were paid in the reporting year. The portion that the ABCC Policy has been communicated to includes those who were issued formal Purchase Orders which include links to the Policy. Alamos is working toward routinely meeting 100% for this figure. ↩