Sustainably Designed

Thacker Pass' energy strategy relies significantly on the self-generation of carbon-free energy through waste heat capture from the sulfuric acid plant (“SAP”). This is expected to generate approximately 90 MW per year of electricity for Phase 1 and 2. Benefits of the co-located SAP include a reduction of Scope 1 and Scope 2 carbon emission intensity per tonne of lithium carbonate produced and eliminating the need to truck sulfuric acid to site, which should reduce the number of transports to site by approximately two-thirds (Scope 3 carbon emissions). As a result, the projected Scope 1 and 2 emission intensity for Thacker Pass is expected to 40% less than its mining peers (when processing is included). The Company is working towards baselining projected Scope 3 emissions.

We are committed to reducing our biodiversity impacts, to protecting local species, cultures and natural ecosystems and to integrating conservation into the design and life cycles of our projects and operating activities. We are actively involved in managing, protecting and mitigating habitats and ecosystems in our project areas, and have invested over $1 million in environmental projects that included restoration of sage grouse habitat, eagle mitigation and riparian stream rehabilitation.

Over the past 12 years, we have carefully studied the ecosystem that surrounds Thacker Pass, and have made several key design decisions based on biodiversity considerations including:

• Moving the project's location out of the Montana Mountains to protect sensitive species. The mountains support streams, wildlife and vegetation, while Thacker Pass is dry and dominated by sage brush that has sustained fire damage and is therefore considered a lower-quality habitat area.
• Building stringent requirements into the project from this early stage, including planning and permitting as well as various monitoring and mitigation measures.
• Committing to funding sage grouse habitat restoration in Northern Nevada.
• Committing to funding stream-habitat restoration projects by the Nevada Division of Wildlife north of the project area

Thacker Pass is designed to store tailings using the filtered dry stacked method. Dry stacking is considered to be the safest, most stable and most sustainable method of tailings storage, as it eliminates the need for a traditional slurry tailings dam and results in zero liquid effluents leaving the process (as per our Zero Liquid Discharge design). The significant amount of water obtained from filtering the tailings facilitates water recycling and reuse, and ultimately saves water that would otherwise be drawn from the groundwater aquifer.

From the outset, we have incorporated water stewardship considerations into our project decisions and design ‐ a reflection of our driving focus on using water efficiently and limiting water quality impacts.

Thacker Pass is being designed for low water consumption. The majority of the water needs for the project will be met with recycled water. Any water drawn will be reused and recycled an average of seven times within the production process. We are designing the operation as a Zero Liquid Discharge facility, which is intended to prevent the discharge of industrial wastewater into the environment. This is an extensive commitment because it means all water that is filtered from tailings must be evaporated or recycled for reuse within the site's production process.

To minimize the cumulative impact of water withdrawal on the local aquifer, Thacker Pass will use existing water rights so that the overall withdrawal volume is consistent with past years. Additionally, when water rights were transferred from agricultural use to industrial use, nearly a quarter (22.5%) of the total allowable withdrawal volume was returned to the state of Nevada. No additional water rights are required for Phase 1.

In February 2022, Thacker Pass received a Water Pollution Control Permit from the Nevada Division of Environmental Protection Bureau of Mining Regulation and Reclamation, which authorizes the construction, operation and closure of the mine in accordance with limitations/conditions set forth in the permit.

Complying with all environmental laws and regulations where we operate, including where applicable, compliance with international declarations, conventions and treaties, as well as national, sub-national, regional and local regulations.

The Initiative for Responsible Mining Assurance (IRMA (opens in new window)) is currently among the most stringent ESG standards for mining. In September 2021, we joined as an IRMA Pending Member, which means we commit to having Thacker Pass audited against the new draft IRMA Ready Standard for exploration and development within 12 months of the standard's availability for application. In early 2022, we piloted the new IRMA Ready Standard for Responsible Mineral Exploration and Development at Thacker Pass. We are currently undertaking a gap analysis, to address areas of opportunities for improvement, in preparation of commencing an external audit upon adoption of the IRMA Ready framework in 2024.

The U.S. federal courts affirmed our regulatory compliance and environmental integrity. Following a two-year review, on February 6, 2023, the Federal Court rejected arguments that Thacker Pass will cause unnecessary and undue degradation to the local sage grouse population and habitat, groundwater aquifers and air quality; and that the Bureau of Land Management (BLM) failed to adequately assess the project's impacts on air quality, wildlife and groundwater. The Federal Court also rejected arguments that the BLM failed to adequately consider the impact of Thacker Pass on culturally or historically significant properties; and that BLM acted unreasonably or in bad faith in identifying Indigenous tribes for consultation before approving the project. Subsequently, in mid-July 2023, the Ninth Circuit court unanimously affirmed the Federal Court's ruling including the decision to not vacate the Record of Decision (originally issued in January 2021).