TOXIC REDUCTION POLICY STATEMENT OF INTENT

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1 TOXIC REDUCTION POLICY STATEMENT OF INTENT De Beers Canada Inc., is committed to playing a leadership role in protecting the environment. Our employees are encouraged to participate in all types of toxic substance reduction activities. Toxic substance reduction will be an ongoing effort at DeBeers, and we will continue to monitor advancements to ensure that options that are both technologically and financially viable are implemented at our facility. Metals are not created or used at the DeBeers site but are naturally contained in ore (kimberlite) from which diamonds are extracted. After processing, the coarse processed kimberlite (CPK) is stockpiled and the fine processed kimberlite (FPK) is transferred to an onsite tailings management pond. The FPK and CPK transferred to the tailings pond or stockpiles contains arsenic, cadmium, chromium, hexavalent chromium, cobalt, copper, lead, manganese, nickel, selenium, thallium, vanadium and zinc. The stockpiled CPK will be part of the mine reclamation once it is decommissioned. There are also trace amount of metals emitted and transferred from the operation of the onsite incinerator. This represents less than 0.01% of the total metals reported. DeBeers already employs waste diversion to reduce the amount of plastics and metals entering the incinerator, in addition the incinerator is equipped with advanced air pollution control (scrubbers) to minimize emissions to air. REDUCTION OBJECTIVES DeBeers does not intend to reduce the transfer of metals because these substances are naturally occurring in ore from which diamonds are extracted and eventually disposed into the onsite tailings management pond. The only way to reduce the amount of metals transferred to the tailings facility would be to reduce the amount of ore processed, which could only be obtained by reducing output and plant operations. DeBeers is committed to ensuring their tailings transfers are handled in a safe and responsible manner. While DeBeers does not intend to reduce the transfer of the aforementioned metals, technologies that may reduce the releases to the environment of these substances will be monitored. PLAN SUMMARY STATEMENT This plan summary accurately reflects the content of the toxic substance reduction plan for Metals (arsenic, cadmium, chromium, hexavalent chromium cobalt, copper, lead, manganese, nickel, selenium, thallium, vanadium and zinc) prepared on behalf of De Beers Canada Inc., dated December 19, BASIC FACILITY INFORMATION Company Name: DeBeers Canada Inc., Contact Information: 119 Pine St. South, Suite 310, Timmins, ON. P4N 2K3

2 Highest Ranking Employee: James Kirby Mine General Manager Ext Technical Contact: Certified Planner: Parent Company: Anne L. Boucher (Acting Environmental Superintendent/ DeBeers Mining Canada ext Tony van der Vooren P.Eng, Ph.D, QEP License Number TSRP0051 Senior Environmental Consultant Amec Foster Wheeler Environment and Infrastucture De Beers Canada Inc. 100% ownership. Address: Airport Road NE Calgary, Alberta T2E 6Z8 Business Number: The facility s NPRI ID: full time employees (equivalent). Site Location (UTM Coordinates): Zone 17, E and N The NAICS codes applicable to the facility are: 21 Mining, quarrying, and oil and gas extraction 2123 Non metallic mineral mining and quarrying Diamond Mining Company Name: DeBeers Canada Inc. This Toxic Reduction plan was prepared for arsenic, cadmium, hexavalent chromium, chromium, cobalt, copper, lead, manganese, nickel, selenium, thallium, vanadium and zinc. Separate toxic reduction plans have been developed for dioxins and furans individual congeners, hexachlorobenzene, carbon monoxide and particulates (TPM, PM10 and PM2.5).

3 Manganese NA-09, Thallium NA-37,

4 CERTIFICATION OF HIGHEST RANKING EMPLOYEE As of December 19, 2017, I, James Kirby, certify that I have read the toxic substance reduction plan for the toxic substance referred to below and am familiar with its contents, and to my knowledge the plan is factually accurate and complies with the Toxics Reduction Act, 2009 and Ontario Regulation 455/09 (General) made under that Act (except for the plan submission by Dec 31, 2012). (This plan was originally finalized and certified Dec 23, This certification is for an update to the plan, as of Dec 19, 2017 to account for the addition of hexavalent chromium and thallium). Manganese NA-09, Thallium NA-37 James Kirby General Manager

5 CERTIFICATION OF LICENSED PLANNER As of December 19, 2017, I, Tony van der Vooren certify that I am familiar with the processes at DeBeers that use or create the toxic substance referred to below, that I agree with the estimates referred to in subparagraphs 7 iii, iv and v of subsection 4 (1) of the Toxics Reduction Act, 2009 that are set out in the plan dated [insert version date] and that the plan complies with that Act and Ontario Regulation 455/09 (General) made under that Act (except for the plan submission by Dec 31, 2012). (This plan was originally finalized and certified Dec 23, This certification is for an update to the plan, as of Dec 19, 2017 to account for the addition of hexavalent chromium and thallium). Manganese NA-09 Thallium NA-37, Tony van der Vooren P.Eng, Ph.D, QEP Licensed Toxic Reduction Planner (Ontario): License Number TSRP0051 Senior Environmental Consultant Amec Foster Wheeler Environment and Infrastructure