OSC enforcement: The Whistleblower Program......From the historical evidence, STGO used either "Selective disclosures" or "Aftermath facts" (not followed by "Timely disclosure") for "material facts" ....
1. Crusher crash - violating "NP - 51- 201 - Disclosure Standards" 4.3 "Changes in Business and Operations - any development that affects the company's resources, technology, products or markets "....well known speech from STGO's mngmnt is "i told it to major shareholders" ....
2. BoD/Executive team key member changes - violating same section above "changes to the board of directors or executive management, including the departure of the company's CEO, CFO, COO or president (or persons in equivalent positions)" ... "1 BoD member & 1 Exec.team member unexpectedly disappears, shareholders knew it only when got AGM - Mngmnt information circular" after 6 or more months that events occurs ..... NP - 51- 201 : "A company must also file a material change report as soon as practicable, and no later than 10 days after the change occurs"
3. Outdated economic projection - violating "National Instrument 43-101 Standards of Disclosure for Mineral Projects" / Companion Policy 43-101CP Standards of Disclosure for Mineral Projects - Shelf Life of Technical Reports ... this section relates to National Policy: NP - 51- 201 - Disclosure Standards: Changes in Financial Results: "a significant increase or decrease in near-term earnings prospects" ... STGO released 3 prospectus & 2 technical reports. All those official documents containing economically profitable projection LOM (life of mine period) starting from 2019. ???? 2018 - 2021 Q results shows big loss & negative CF
4. Unfounded / Unreasonable cost increase in phase - II, + $50M - violating NP - 51- 201 : Timely Disclosure: Announcements of material changes should be factual and balanced ...A company's press release should contain enough detail to enable the media and investors to understand the substance and importance of the change it is disclosing ..... Means Covid-19 risk is not a reason... Best practices OSC suggesting is : "companies should expand the scope of their interim management's discussion and analysis disclosure ("MD&A") ... More comprehensive MD&A can have practical benefits, such as more accurate forecasts with fewer revisions"...
I'm eliminated 2 cases that might recognizable as "material", 1 - Local herders protest, was escalated to UN human right committee, 2 - Court case of local mining subcontractor....
National Policy: NP - 51- 201 - Disclosure Standards:
It is fundamental that everyone investing in securities have equal access to information that may affect their investment decisions. The Canadian Securities Administrators ("the CSA" or "We") are concerned about the selective disclosure of material corporate information by companies to analysts, institutional investors, investment dealers and other market professionals.
Selective disclosure occurs when a company discloses material nonpublic information to one or more individuals or companies and not broadly to the investing public. Selective disclosure can create opportunities for insider trading and also undermines retail investors' confidence in the marketplace as a level playing field......The timely disclosure requirements and prohibitions against selective disclosure are substantially similar everywhere.....
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Ref:
https://www.osc.ca/en/securities-law/instruments-rules-policies/5/51-201/national-policy-np-51-201-disclosure-standards
https://www.osc.ca/en/enforcement/osc-whistleblower-program
https://www.osc.ca/en/industry/companies/industry-specific-disclosure-requirements/specific-disclosure-requirements-mining-and-oil-and-gas-companies