• Governance

    Policies and Responsibilities

    1. Does the Board / highest governance body or most senior executive of the company:

    2. Does the company have a publicly stated commitment regarding the following sustainability topics?

    No, this is not a current priority

    No, but we plan to have a commitment within 2 years

    Yes, and the commitment is focused on our own operations

    Yes, and the commitment includes our own operations and the value chain

    Yes, and the commitment includes our own operations and the value chain along with communities and society

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    3. Does the company have in place a code of conduct regarding each of the following sustainability topics?

    No, this is not a current priority

    No, but we plan to have a code of conduct within two years

    Yes, focused on employee conduct

    Yes, focused on employees and suppliers

    Yes, focused on employees, suppliers, and other business relationships

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    4. Has the company appointed an individual or group responsible for each of the following sustainability topics?

    No one is specifically responsible for this topic

    Yes, with limited influence on outcomes (e.g., limited access to internal information, limited decision-making authority)

    Yes, with moderate influence on outcomes (e.g., has access to relevant information, reports to senior manager)

    Yes, with direct influence of some outcomes (e.g., has access to relevant information, includes one or more senior manager with decision making rights

    Yes, with direct influence at the highest levels of the organization (e.g., has access to relevant information, includes most senior members of organization)

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    5. Does the company have a formal structure(s) (such as a cross-functional committee) to address each of the following sustainability topics?

    No formal structure

    Yes, and with limited influence on outcomes (e.g., limited access to internal information necessary to understand risks, poor representation from relevant departments or functions)

    Yes, with moderate influence on outcomes (e.g., it includes representatives of some functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, reports to senior manager)

    Yes, with direct influence on some outcomes (e.g., it includes representatives of functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, it involves one or more members of senior management)

    Yes, and with direct influence at the highest level of the organization (e.g., full access to relevant information, it involves members at highest level of organization)

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Prevention

    6. Does the company have a process or processes to assess risk?

    No, this is not a current priority

    No, but we are planning to develop one in the next two years

    Yes, related to our own operations

    Yes, related to our own operations and entire value chain and other business relationships

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    7. Does the company have a due diligence process through which it identifies, prevents, mitigates, and accounts for actual and potential negative impacts on sustainability topics?

    No, this is not a current priority

    No, but we are planning to develop one in the next two years

    Yes, related to our own operations

    Yes, related to our own operations and entire value chain and other business relationships

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    Concerns and grievance mechanisms

    8. Are there any processes through which members of the company’s workforce can raise concerns about the company’s conduct related to human rights, labour rights, environment, or anti-corruption?

    8.1. Please provide additional detail regarding the process(es) the company has through which members of the company’s workforce can raise concerns about the company’s conduct.

    No

    Yes

    Is the process communicated to all employees/workers in local languages?

    Is the process available to non-employees (e.g., contractors, vendors, suppliers)?

    Is the process confidential (e.g., whistleblowing process)?

    Are there processes in place to avoid retaliation?

    Can concerns be raised about suppliers or other business relationships (e.g., clients, partners, etc.)

    Other (Please provide additional information)

    9. Does the company provide or enable access to effective remedy to right holders / stakeholders where it has caused or contributed to the adverse impact?

    No process to enable remedy to stakeholders

    Remedy available to some stakeholders (i.e., some geographies, employees only)

    Remedy is available to all affected stakeholders

    Remedy is available to all stakeholders, and suppliers are expected to have similar policies

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Lessons

    10. How does the company capture lessons regarding each of the following sustainability topics?

    No lessons are regularly captured

    Conducts root cause analyses/investigation of major incidents

    Conducts root cause analyses/investigation and changes organizational policies, processes, and practices accordingly

    Systematically conducts root cause analyses/investigation and leverages learnings to influence both internal and external affairs

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Executive Pay

    11. Is executive pay linked to performance on one or more of the following sustainability topics?

    No, and we have no intention to change

    No, but we plan to within two years

    Yes

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Board Composition

    12. Percentage of individuals within the company’s Board / highest governance body by:

    Number/Percentage

    Not applicable (Please provide additional information)

    Total number of board members (#)

    7

    Male (%)

    57

    Female (%)

    43

    Non-binary (%)

    Under 30 years old (%)

    0

    30-50 years old (%)

    14

    Above 50 years old (%)

    86

    From minority or vulnerable groups (%)

    0

    Executive (%)

    14

    Independent (%)

    57

    13. Do you produce sustainability reporting according to:

    Data Assurance

    14. Is the information disclosed in this questionnaire assured by a third-party?

    Lucara Diamond Corps annual Sustainability Report includes a third-party assurance audit. The annual reports and GRI Data Tables have been uploaded. Website link to the documents is: https://lucaradiamond.com/sustainability/sustainability-reports/
    At the time of completing this questionnaire, our third-party assurance had not been completed. Our previous annual sustainability reports submitted to the UNGC have been third-party assured under the "Reasonable assurance for majority of metrics" category. We anticipate our assurance to be completed by end of July 2022.
  • Human Rights

    Materiality / Saliency

    1. Which of the following has the company identified as material human rights issues connected with its operations and/or value chain, whether based on their salience (i.e., the most severe potential negative impacts on people) or another basis?

    Optional comment
    This question seems to have a glitch. We were not able to check all of the appropriate boxes.

    Response

    8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the human rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

    We continue to uphold the principles of freedom of association, the elimination of forced or compulsory labour, the effective abolition of child labour, and the elimination of discrimination in respect of employment and occupation. We continued with our regular consultation and negotiation meetings with the Union in 2021, to further strengthen our relationship. This led to the development of key documents like the Employee Consultation & Participation on Occupational Health and Safety Agreement between the Parties, and an updated Relationship Building by Objectives. We continue to support the Union to attend conferences and provide time off work to attend union-related activities. In 2021, we invited members of the community from Moreomaoto, Xere, Xhumo, Rakops, Mmadikola and Toromoja villages, to take part in our first aid training initiative. A total of approximately 35 community members participated. We also partnered with the Motor Vehicle Accident Fund on a national campaign to produce and present videos aimed at sensitizing the viewers on first aid steps for everyday accidents they may encounter. In line with the 2030 United Nations Sustainable Development Goals, our CSI programs have made a substantial impact on lives in Batswana. Our business partners and our communities have also embraced the SDGs, as demonstrated by activities that they partake at a local level. We have seen achievements in the areas of food security, quality education, provision of clean water to communities, development and support of sports at the grassroots level, fight against gender-based violence and ensuring that dignity is restored in affected groups like women and girls. This year we increased our efforts to deal with mental health among our employees, as we partnered with ICAS to provide specialized mental health care to our employees and their spouses. Our efforts in the fight against GBV earned the best corporate award at the ceremony organized by UNDP in partnership with Men and Boys for Gender Equality.
  • Labour

    Commitment

    1. Does the company have a policy commitment in relation to the following labour rights principles?

    No, and we have no plans to develop a policy

    No, but we plan to in the next two years

    Yes, included within a broader policy

    Yes, articulated as a stand-alone policy

    Not applicable (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    2022

    Child labour

    2022

    Non-discrimination in respect of employment and occupation

    2022

    Occupational safety and health

    2022

    Working conditions (wages, working hours)

    2022
    Optional comment
    Policies are reviewed annually. Website link to policies: https://lucaradiamond.com/about-us/corporate-governance/

    1.1. For each labour rights policy, is it:

    Aligned with international labour standards?

    Publicly available?

    Approved at most senior level of the company?

    Applied to the company’s own operations?

    Applied to the company’s supply chain and/or other business relationships?

    Developed involving labour rights expertise from inside and outside the company?

    Other (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Optional comment
    2021 Sustainability Report and GRI Index Tables have been uploaded as well as a number of relevant policies.

    Prevention

    2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following labour rights issues?

    No engagement on this topic

    To better understand the risks/ impacts in question

    To discuss potential ways to prevent or mitigate the risks/ impacts in question

    To agree on a way to prevent/ mitigate the risks/ impacts in question

    To assess progress in preventing/ mitigating the risks /impacts in question

    To collaborate in the prevention/ mitigation of the risks/ impacts in question

    Other (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this labour rights issue?

    Provided internal training/ capacity building for the direct workforce

    Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)

    Conducting an audit process and/or corrective action plan

    Collective Action with peers or other stakeholders, in particular workers' organizations, to address the issue

    Collaboration with governmental or regulatory bodies

    Other (Please provide additional information)

    No action within reporting period

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    4. Who receives training for the following labour rights issues?

    No training provided

    Select employees

    All employees

    Contractors

    Direct suppliers of the organization

    Indirect suppliers of the organization

    Other – such as partners, clients, etc.

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    5. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following labour rights issues?

    No monitoring of progress

    Review issues on ad-hoc basis

    Set annual targets/ goals, track progress over time (internal programs only)

    Set annual targets/ goals, track progress over time (internal and external programs)

    Other (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Performance

    6. What is the percentage of employees covered under collective bargaining agreements?

    Percent of employees (%)

    Unknown

    Employees covered under collective bargaining (%)

    61

    7. What is the percentage of employees in a trade union or other workers' organization?

    Percent of employees (%)

    Unknown

    Not applicable (Please provide additional information)

    Employees in a trade union or on a worker committee (%)

    61

    8. In the course of the reporting period, what was the percentage of women in:

    Percent of women (%)

    Unknown

    Senior leadership level position

    75

    Non-executive board

    29

    9. What was the average ratio of the basic salary and remuneration of women to men (comparing jobs of equal value) during the reporting period?

    Salary ratio (%)

    Unknown

    Choose to not disclose

    Women / Men (%)

    100
    Optional comment
    There is no gender pay disparity comparing jobs of equal value within the company.

    10. In the course of the reporting period, how frequently were workers injured (injuries per hour worked)?

    Frequency of injury

    Unknown

    Choose to not disclose

    Frequency of injury

    0

    11. In the course of the reporting period, what was the company’s incident rate?

    Incident rate

    Unknown

    Choose to not disclose

    Incident rate

    0

    Response and Reporting

    12. In the course of the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to the adverse impact associated with the following labour rights issues?

    Yes

    No

    Choose to not disclose

    Not applicable (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    13. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the labour rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

    We promote equal opportunities throughout the recruitment process of our work force. In 2021, we provided or financed over 25,840 training hours across all departments to continue to up-skill our employees. We also actively encourage women to apply for all of our positions, including those available with our contractors. Lucara Botswana introduced the Talent Management Initiative in 2021. A total of 28 students (all citizens from Botswana) from various local and international universities were afforded experiential learning across all disciplines of our organization. In 2021, we introduced progressive benefits, such as a 6-months maternity leave for our female employees, and paternity leave of 2 weeks for our male employees. Previously, maternity leave was 84 days (three months) and there was no paternity leave. Instead of the statutory 25 percent pay during maternity leave, our employees receive 100 percent of wages for up to three children. The company also moved all its employees to a better medical aid option, and increased the maximum employer contributing amount by over 100%. This means that most of our employees will receive free medical aid. In 2021, we implemented our new human resources system. We continue to uphold the principles of freedom of association, the elimination of forced or compulsory labour, the effective abolition of child labour, and the elimination of discrimination in respect of employment and occupation. We maintain a formal and tiered grievance procedure. The mine has adopted an Occupational Health and Safety Management System based on the ISO 45001:2018 standard. Through teamwork and dedication displayed by the various departments and business partners, the mine successfully attained its first certification in November 2021. We promote a culture of health and wellbeing. We maintain on-site health care unit at Karowe. It is staffed by two consulting doctors and a nurse offering primary health care, a wellness program, and occupational health services to the entire workforce. In addition to conducting preemployment and periodic medical exams, the medical and health program also covers HIV/AIDS, tuberculosis, obesity, diabetes, and hypertension. In response to COVID-19, we also continued a counselling service for our workforce.
  • Environment

    Commitment

    1. Does the company have a formal policy on the following environmental topics?

    No, and we have no plans to develop a policy

    No, but we plan to in the next two years

    Yes, included within a broader policy

    Yes, articulated as a stand-alone policy

    Not applicable (Please provide additional information)

    Climate Action

    2022

    Water

    2022

    Oceans

    We do not operate near any oceans, rivers or lakes.

    Forests / Biodiversity / Land Use

    2022

    Air Pollution

    2022

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    2022

    Energy & Resource Use

    2022
    Optional comment
    2021 Sustainability Report and GRI Index Tables have been uploaded as well as relevant policies. Policies reviewed annually.

    1.1. For each environmental policy, is it:

    Aligned with international environmental standards?

    Publicly available?

    Approved at most senior level of the company?

    Applied to the company’s own operations?

    Applied to the company’s supply chain and/or other business relationships?

    Developed involving environmental expertise from inside and outside the company?

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    Prevention

    2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following environmental issues?

    No engagement on this topic

    To better understand the risks/ impacts in question

    To discuss potential ways to prevent or mitigate the risks/ impacts in question

    To agree on a way to prevent/ mitigate the risks/ impacts in question

    To assess progress in preventing/ mitigating the risks/ impacts in question

    To collaborate in the prevention/ mitigation of the risks/ impacts in question

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with these environmental topics?

    Provided internal training/ capacity building for the direct workforce

    Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)

    Conducting an audit process and/or corrective action plan

    Collective Action with peers or other stakeholders to address the issue

    Collaboration with governmental or regulatory bodies

    Other (Please provide additional information)

    No action within reporting period

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    4. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?

    No monitoring of progress

    Review issues on ad-hoc basis

    Set annual targets/ goals, track progress over time (internal programs only)

    Set annual targets/ goals, track progress over time (internal and external programs)

    Other (Please provide additional information)

    Climate Action

    We are in the process of undertaking a feasibility study looking at increasing our use of renewable energy, namely solar. We are currently participating in the UNGC Climate Accelerator Program and will be developing targets and goals this year.

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    See comment under Climate Action

    5. In the course of the reporting period, has the company been involved in providing or enabling remedy for any actual impacts associated with the following environmental issue(s)?

    Yes

    No

    Choose to not disclose

    Not applicable (Please provide additional information)

    Climate Action

    Water

    Oceans

    We do not operate near any oceans, rivers or lakes

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    Climate Action

    6. What were the company’s gross global greenhouse gas emissions for the reporting period?

    Scope 1 Emissions

    Emissions (tCO2e)

    16618

    Scope 2 Emissions

    Emissions (tCO2e)

    58494

    Scope 3 Emissions

    We have not yet defined our Scope 3 emissions. This is work that we are undertaking this year.

    Emissions (tCO2e)

    Optional comment
    We are in the process of defining our Scope 3 emissions.

    7. What percentage of the company's revenue was invested in R&D of low-carbon products/services during this reporting period?

    Percent of revenue (%)

    8. Has the organization acted to support climate change adaptation and resilience?

    In 2021, we completed a Climate Change Risk Assessment and further reviewed transition and physical risks to our operations. Physical risks may include disruption of power supply due to unusual seasonal rainfall events. As in previous years, we experienced such impacts during heavy rainfall events in 2021, in addition to impacts from planned and unplanned outages by BPC. The on-going construction a new transmission line with an estimated investment cost of approximately $18 million will help reduce power interruption risks Other risks may include carbon-related cost escalation, and competitive or market pressure, both of which could be mitigated by including renewable power into our power mix at Karowe, which we expect to pursue guided by the outcome of the feasibility study. Climate-related opportunities include cost savings by adopting solar PV and battery storage as part of our power mix. Other opportunities relate to Clara, our digital sales platform. It can support buyers to reduce or eliminate the need for in-person viewing of rough diamonds, thus reducing their travel-related GHG emissions.
    Optional comment
    We are participating in the Climate Accelerator Program and are undertaking a feasibility study to increase our use of alternative energy. In 2021 we installed rooftop solar panel on our administrative and office buildings. Some of our community investments have included the installation of solar panels. The learnings from participating in the program and the results of the feasibility study will feed in to our climate change risk and adaptation work planned for the future.

    Energy / Resource Use

    9. Please report the company's renewable energy consumption as a percentage of total energy consumption in the reporting period.

    % of total energy consumption

    0

    Technology

    10. What percent of the company's revenue came from environmentally friendly products / services during this reporting period?

    Percent of total revenue (%)

    Sector-specific Questions

    11. Which sector(s) does the company operate in? If diversified, choose top 3 by revenue.

    Sector-specific: Water

    12. Please provide details regarding the company's water withdrawal and consumption (own operations) during the reporting period.

    Water withdrawal (volume of water in megaliters):

    Mega-liters

    Unknown

    Not applicable (Please provide additional information)

    Total

    1942618

    Groundwater:

    1942618

    Surface water:

    0

    Rainwater:

    0

    Wastewater:

    0

    Percentage of water withdrawn in regions with high or extremely high water stress (%)

    100

    Water consumption (volume of water in megaliters):

    Mega-liters

    Unknown

    Not applicable (Please provide additional information)

    Total

    1339833

    Groundwater:

    1339833

    Surface water:

    0

    Rainwater:

    0

    Wastewater:

    0

    Percentage of water consumed in regions with high or extremely high water stress (%)

    100
    Optional comment
    Lucara has a water sharing agreement with a neighbouring mining company and pipes excess water to that mine. The groundwater aquifer that Lucara draws from is not potable. The neighbouring mine shares their groundwater aquifer with a neighbouring village. By sharing excess water with the neighbouring mine, Lucara assists that company with reducing their use of that potable groundwater aquifer.

    13. Please provide details about the company’s water intensity of products in regions with high or extremely high water stress.

    Water intensity of products (cubic meter/$):

    No freshwater is used in our operations.

    Sector-specific: Forest, biodiversity, and land use

    14. Please report the number and area (in hectares) of sites owned, leased, or managed by the company in or adjacent to protected areas and/or key biodiversity areas (KBA).

    Number

    Unknown

    Not applicable (Please provide additional information)

    Sites

    0

    Hectares

    0

    15. What area (in hectares) of natural ecosystems was converted during the reporting period in areas owned, leased, or managed by the company?

    Conversion of natural resources (hectares)

    The area that the mine was built was already modified habitat. The area is surrounded by farms and grazing lands. The area has been historically over-grazed.

    16. Is the company supporting or implementing project(s) focused on ecosystem restoration and protection?

    No

    No, but we plan to in the next 2 years

    Yes

    Forest ecosystem restoration

    Other ecosystem restoration

    Reforestation

    Natural regeneration

    Agroforestry

    Set-aside land

    Biodiversity offsetting

    Other (please specify in text box)

    Optional comment
    Lucara has an approved Closure Plan which includes progressive reclamation. The company has a Biodiversity Management Plan and is undertaking revegetation trials. This is something that we are looking at in the near future, not sure if it will be in the next 2 years.

    Sector-specific: Air pollution

    17. Where applicable, please report the company's emissions of the following pollutants during the reporting period.

    Emissions (tCO2e)

    Unknown

    Not applicable (Please provide additional information)

    NOx

    SOx

    Volatile Organic Compounds (VOC)

    Hazardous air pollutants (HAP)

    Particulate matter (PM10)

    Persistent organic pollutants (POP)

    Other (please specify in text box)

    Sector-specific: Waste

    18. Please report the company's total weight of waste generated in metric tonnes during the reporting period.

    Waste Generated (t)

    19. Please report the percentage of the company's waste that was hazardous waste (i.e., hazardous waste ratio) during the reporting period.

    Hazardous Waste Ratio (%)

    20. Please report the company's estimated metric tonnes of single-use plastic consumed wherever material along the value chain during the reporting period.

    Single-use plastics (tonnes)

    Overall Environment

    21. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the environment principles, including any challenges faced and actions taken towards prevention and/or remediation.

    In 2021, as part of our collaboration with the Water Utilities Corporation and the Debswana Diamond Mining Company, we were able to direct 474,430 m3 of surplus water to Debswana’s Orapa Diamond Mine. In 2021, we benchmarked ourselves using the recommendations of the Task Force for Climate-related Financial Disclosure (TCFD), externally verified our self-assessment against the Mining Association of Canada’s Towards Sustainable Mining Climate Change Protocol, established a climate change committee, and identified suitable decarbonization pathways. We have also initiated renewable energy as a priority in our community development projects. With enabling changes introduced by BPC, we piloted the installation of a 120kWp rooftop solar PV system at the administration block at the Karowe Mine in 2021. We expect to have the installed system inspected, approved for use by the Botswana Energy Regulatory Authority (BERA) and grid connected in early 2022. The expected annual energy yield and CO2 reduction over 20 years are 194 MWh and 1,306 tCO2e, respectively. Further pilot projects are planned for 2022 and 2023. By 2021, over 60 percent of the plant lights were converted to LED lights in an effort to improve our energy efficiency. We plan to phase out non-led lighting over the next five years. Procurement specifications have been updated to accommodate this change. Other energy efficiency opportunities have also been considered, such as further optimizing process plant controls and converting to more energy efficient variable speed drives. In 2021, we completed a Climate Change Risk Assessment and further reviewed transition and physical risks to our operations. In 2021, we updated our Biodiversity Management Plan and completed an external verification of our self-assessment of the Mining Association of Canada’s Towards Sustainable Mining Biodiversity Protocol. In response to feedback from our materiality workshop and findings described above, biodiversity was elevated to a material topic.
  • Anti-corruption

    Commitment

    1. Does the company have an anti-corruption compliance programme?

    2022
    Optional comment
    Reviewed annually

    2. Does your company have policies and recommendations for employees on how to act in case of doubt and/or in situations that may represent a conflict of interest, e.g. with regard to gifts and hospitality, donations, sponsorship, or interactions with public officials?

    Optional comment
    Policy uploaded. Website link to policies: https://lucaradiamond.com/about-us/corporate-governance/

    Prevention

    3. Who receives training on anti-corruption and integrity?

    3.1. How often is such training provided?

    One time only

    Every year

    Every two or more years

    We do not collect this data

    All employees

    Select employees

    Contractors

    Direct suppliers of the organization

    Other – such as partners, clients, etc.

    Indirect suppliers of the organization

    4. Does the company monitor its anti-corruption compliance programme?

    Response and Reporting

    5. Please report the company's total number and nature of incidents of corruption during the reporting year.

    Number of incident(s)

    Unknown

    Choose to not disclose

    Confirmed during the current year, but related to previous years

    0
    There weren't any

    Confirmed during the current year, and related to this year

    0
    There weren't any

    6. Within the reporting period, what measures has the company taken to address suspected incidents of corruption independently or in response to a dispute or investigation by a government regulator?

    7. Does your company engage in Collective Action against corruption?

    Annual training and disclosure requirements with regard to procurement and contracts, ESTMA filing

    8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the anti-corruption principle, including any challenges faced and actions taken towards prevention and/or remediation.

    We provide annual training to all employees and contractors. As part of our internal controls over financial reporting and our internal audits, we look for evidence of fraud and/or corruption.