The Issuer included corrective disclosures in its Management’s Discussion & Analysis for the annual period ended December 31, 2021 to remedy deficiencies identified in previously filed documents, including disclosures related to the Issuer’s business and operations, description of significant projects without revenue, liquidity and capital resources, related party transactions and material forward looking information.

Reasons for Refilings: The Company amended and refiled its March 31, 2022 and December 31, 2021 Management Discussion and Analysis (“MD&A”) to enhance disclosure relating to, among other things, COVID-19 impacts, current projects of the Company and their status, overall performance, and discussions of operations, including its SponsorCoin Platform and the Hemp products and Vitamin Shots marketplace and the Ready to Drink (“RTD”) spirits and premium spirits, transactions between related parties, and liquidity and cash resources. The Company has also enhanced its disclosure regarding the regulatory framework relating to regulated Hemp and Alcohol products in each jurisdiction where the Company operates. The Company also filed a material change report regarding the appointment of Charles Sung as the CFO on March 9, 2022.

AIF and Technical Report did not comply with NI 43-101 (deficiency 2

Reasons for Refilings: The Company has enhanced disclosure within its Management’s Discussion & Analysis (MD&A) for the year ended December 31, 2021, relating to, among other things, overall performance, discussions of operations, including emerging market operations and the contributing growth factors, transactions between related parties, and liquidity and cash resources. The Company has also remedied prior period reporting deficiencies including providing comparative year-to-date results in the MD&A, segregation of EBITDA and adjusted EBITDA as a non-GAAP measure and disclosure regarding the regulatory framework in each jurisdiction where the Company operates. The Company has filed a material contract for a licensing and trademark agreement that had not been previously filed.

The Issuer has included enhanced disclosure in its Management’s Discussion & Analysis (MD&A) for the year ended December 31, 2021, addressing comments from Staff’s continuous disclosure review of the MD&A for the three and nine months ended September 30, 2021. These enhancements relate to, among other things, its description of business, liquidity and cash resources, discussion of operations, anticipated business operations, forward-looking information, and COVID-19 disclosures.

The issuer refiled a business acquisition report as the original filing did not contain a complete set of interim financial statements.

The Issuer restated its annual financial statements for the year ended December 31, 2020 (the Restated Financial Statements) and associated Management Discussion & Analysis (MD&A). The Restated Financial Statements and MD&A were restated to correct an error relating to the Issuer’s accounting treatment for its metal stream agreement with Triple Flag Finance Bermuda (the Stream Agreement). The correction of this error resulted in the Issuer accounting for the Stream Agreement as a derivative at fair value through profit and loss in its entirety. Furthermore, the correction of this error also resulted in changes to the revenue previously recognized and the presentation of certain items in the Consolidated Statement of Cash Flows.

The Issuer included corrective disclosures in its Management’s Discussion & Analysis for the annual period ended December 31, 2021 to remedy deficiencies identified in previously filed documents, including disclosures related to the Issuer’s business and operations, related party transactions, discussion of operations, liquidity and capital resources, quarterly results, impact of COVID-19, risk disclosures, etc.

The Issuer filed an amended technical report on the Don Mario property to provide one current technical report in respect of a property and to include several areas of required disclosure that were missing.

The Issuer retroactively restated its reporting of non-GAAP financial measures for the years ended June 30, 2022 and interims period ending September 30, 2022 and December 30, 2022 along with comparatives.  Previously, adjusted earnings (loss) and adjusted equity included adjustments to exclude the estimated allowance for credit losses pursuant to IFRS 9 Financial Instruments and include actual credit losses occurred during the period. Other corrective disclosures were also made to comply with National Instrument 52-112 Non-GAAP and Other Financial Measures Disclosure.

The website of Connor, Clark & Lunn Funds Inc. included a statement that Connor, Clark & Lunn Funds Inc. seeks to make investments that have a positive impact on the society, environment, and markets in which they operate. This statement had the effect of suggesting that the funds managed by Connor, Clark & Lunn Funds Inc. aim to generate a positive ESG impact. This statement was removed from the website in order to clarify that the consideration of ESG factors is not a component of the investment objectives for any of its publicly offered mutual funds , nor does it form a material element of the investment strategies of those funds.

The Issuer has included enhanced disclosure in its management’s discussion & analysis (MD&A) for the year ended January 31, 2022 and the periods ended April 30, 2022 and July 31, 2022. Corrective disclosure was requested by OSC staff in connection with a review of the Issuer’s application to revoke the failure-to-file cease trade order issued by the OSC on June 6, 2022. Corrective disclosure addresses various deficiencies identified under Form 51-102F1 Management’s Discussion & Analysis, including: investment and fair value disclosures, description of business and discussion of operations, overall performance, summary of quarterly results, liquidity and capital resources, transactions between related parties, investments in emerging markets, and cryptocurrency risks.

The Issuer amended and refiled its Management’s Discussion & Analysis for the year ended February 28, 2022 and the three and nine months ended November 30, 2022 to provide enhanced disclosures of the following: analysis of revenues and expenses, discussion of liquidity and capital resources, disclosure about significant projects in progress, an update on the status of an application with Health Canada and details about the composition of the audit committee and corporate governance practices.

The Company has made certain corrective disclosures in accounting for the consideration payable under the second amended and restated share purchase agreement among SSR Mining Inc., Huayra Minerals Corporation, AbraSilver and Fitzcarraldo Ventures Inc. dated as of March 21, 2017, as amended on December 31, 2017, and as further amended on September 11, 2019 (the “Diablillos SPA”) which previously resulted in an understatement of mineral property interests, consideration payable, accumulated deficit and accumulated other comprehensive loss as at January 1, 2021, and December 31, 2021. The Company previously disclosed the unpaid remaining consideration of US$7,000,000 as a commitment. The Company has now remedied this by recognizing the remaining consideration payable as at January 1, 2021 of US$7,000,000, discounted at 15% discount rate per annum, with an estimated payment date of July 31, 2025. The Company has also recognized a corresponding addition to mineral property interests since the date of the Diablillos SPA, considering the hyperinflation impact in the Company’s subsidiary. The consideration payable has been accreted. 

The website of MD Financial Management Inc. included statements about the consideration of ESG factors as part of the investment process for the funds that it manages. Revisions to the website were made to clarify that certain issuers do not consider ESG factors and to provide more clarity on the funds that do.

The Issuer filed an amended technical report on the Florence Lake property to remove several supplementary and excessive appendices.  

In connection with the Issuer’s previously announced public offering of common shares (the “Offering”) and the review by the Ontario Securities Commission (the “OSC”) of the amended and restated preliminary short form prospectus of the Company dated July 13, 2023, and including the documents incorporated by reference therein (collectively, the “Prospectus”), the Issuer has issued a clarifying press release regarding retraction of certain technical disclosures and removal of non-IFRS measures.

Specifically, the technical report entitled “Molo Phase 2 Preliminary Economic Assessment, National Instrument 43- 101 Technical Report on the Molo Graphite Project located near the village of Fotadrevo, in the Province of Toliara, Madagascar” with an effective date of April 27, 2022 (the “PEA”), as incorporated by reference into the Prospectus, incorrectly included the previously delineated mineral reserve estimate for Phase 1 of the Molo Graphite Mine into the preliminary economic assessment for Phase 2 expansion of the Molo Graphite Mine, in contravention of National Instrument 43-101 – Standards of Disclosure for Mineral Projects. To correct such error, the Issuer retracted the mineral reserve estimate from the PEA and from any other continuous disclosure documents filed by the Issuer and accordingly such mineral reserve statements will not form part of the final prospectus related to the Offering.\

Further, the Issuer is refiling the annual management's discussion and analysis for the years ended June 30, 2022 and 2021 as well as the interim management's discussion and analysis for the period ended March 31, 2023, to remove the references to the mineral reserve statements noted above, and additionally to adjust certain disclosures and remove certain non-IFRS measures previously included relating to the Mauritius BAF.

 A news release was issued to indicate that the Issuer refiled its unaudited financial statements (Financial Statements) and management’s discussion and analysis (MD&A) for the interim period ended December 31, 2022 to include corrective disclosure and to address certain deficiencies identified by Staff in connection with a continuous disclosure review.

Specifically, corrective disclosure addresses various deficiencies identified under Form 51-102 F1, Management’s Discussion & Analysis, including: the reference to the Issuer’s expired letter of intent with Highvista Capital Corp. and the liquidity and capital resources disclosure throughout the MD&A and the Financial Statements.

The Issuer did not previously file its various credit agreements with the Bank of Montreal as material contracts as required by National Instrument 51-102 Continuous Disclosure Obligations (NI 51-102).

The Issuer filed an amended and restated technical report on the Boroo and Ulaanbulag Project to address several disclosure deficiencies including the qualified person and associated certificate, use of the technical report for internal purposes only, and rounding the mineral estimates to appropriate significant figures.