The Canadian Advocacy Council agrees with the broad objectives and principles of this initiative, however, we disagree with the removal of certain disclosure that is currently required within NI 51-101 for the Disclosure of Resources (Section 5.9, formerly Disclosure Concerning Prospects). Our comments in regards to this are outlined in the Specific Comments section below. The CSA as also proposed to remove: 1) the requirement to report reserves and the related future net revenue using constant prices and cost, 2) the requirement to reconcile future net revenue, and 3) the requirement to do a reserves reconciliation using net reserves to doing the reserves reconciliation using gross reserves.
Overview of the Council’s Comments:
To ensure greater independence, the Board rather than the company management, should appoint the independent evaluator given that reserves represent significant assets for companies in the extractive industry. We think this appointment should be integrated with the overall audit of the financial statements.