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Economic Performance

Disclosure Number Disclosure Title Disclosure Requirement Disclosure Response
103-1 Explanation of the material topic and its Boundary a. An explanation of why the topic is material Economic performance is caused by our operations and activities, along with those supporting these across our supply chain.
b. The Boundary for the material topic, which includes a description of:
i. where the impacts occur; 
ii. the organization’s involvement with the impacts. For example, whether the organization has caused or contributed to the impacts, or is directly linked to the impacts through its business relationships.
The boundary for this topic is limited to the jurisdictions of our mining operations.
c. Any specific limitation regarding the topic Boundary Disclosure of financial information is governed by our internal Disclosure, Confidentiality and Insider Trading Policy.
103-2 The management approach and its components a. An explanation of how the organization manages the topic A detailed explanation of how the organization manages its economic performance is outlined in the 2019 Consolidated Financial Statements and 2019 Management's Discussion & Analysis.
b. A statement of the purpose of the management approach The management of economic performance helps the Company maintain its liquidity and reduce its costs.
c. A description of the following, if the management approach includes that component:
i. Policies
ii. Commitments
iii. Goals and targets
iv. Responsibilities
v. Resources
vi. Grievance mechanisms
vii. Specific actions, such as processes, projects, programs and initiatives
2019 Management's Discussion & Analysis

2019 Consolidated Financial Statements
103-3 Evaluation of the management approach For each material topic, the reporting organization shall report the following information: 
a. An explanation of how the organization evaluates the management approach, including:
i. the mechanisms for evaluating the effectiveness of the management approach;
ii. the results of the evaluation of the management approach;
iii. any related adjustments to the management approach.
Each New Gold site adheres to its financial policies and procedures that feed into the overall corporate mandate for all financial information. Financial information is disclosed every quarter.
201-3

Defined benefit plan obligations and other retirement plans

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Disclosure Requirement Disclosure Response
a. If the plan’s liabilities are met by the organization’s general resources, the estimated value of those liabilities New Gold has a Group RRSP plan. The company's responsibility and liability to group RRSP is limited to making payroll contributions. There is no estimated value to liabilities.
b. If a separate fund exists to pay the plan’s pension liabilities:  New Gold has a Group RRSP plan. The company's responsibility and liability to group RRSP is limited to making payroll contributions. There is no estimated value to liabilities.
i. the extent to which the scheme’s liabilities are estimated to be covered by the assets that have been set aside to meet them;  There is no estimate for how much the scheme’s liabilities are covered by the assets that have been set aside to meet them.
ii. the basis on which that estimate has been arrived at;  N/A
iii. when that estimate was made N/A
c. If a fund set up to pay the plan’s pension liabilities is not fully covered, explain the strategy, if any, adopted by the employer to work towards full coverage, and the timescale, if any, by which the employer hopes to achieve full coverage There is no strategy set up. The employee is responsible for the investment selection so any market changes do not create a liability for New Gold.
d. Percentage of salary contributed by employee or employer 7% for sites, 9% for corporate up to the CRA limit.
e. Level of participation in retirement plans, such as participation in mandatory or voluntary schemes, regional, or country-based schemes, or those with financial impact Group RRSP is voluntary. All full time permanent employees are eligible to participate.

Market Presence

Disclosure Number Disclosure Title Disclosure Requirement Disclosure Response
103-1 Explanation of the material topic and its Boundary a. An explanation of why the topic is material New Gold has a meaningful presence in the areas of our operations. New Gold is one of the largest private employers in the Rainy River region and therefore has significant economic impact in this area.
b. The Boundary for the material topic, which includes a description of:
i. where the impacts occur; 
ii. the organization’s involvement with the impacts. For example, whether the organization has caused or contributed to the impacts, or is directly linked to the impacts through its business relationships
The boundary for this topic is limited to the jurisidictions of our mining operations. New Gold contributes locally to indirect economic impacts through investments in education, health, social services, arts & culture, and the environment at each of our operations.
c. Any specific limitation regarding the topic Boundary
103-2 The management approach and its components a. An explanation of how the organization manages the topic New Gold’s local hiring practices are in compliance with laws and regulations and best practices in all areas of operation.
b. A statement of the purpose of the management approach We invest in our employees and strive to provide dynamic career paths with growth opportunities. Empowering people is an essential part of New Gold’s mission and culture.
c. A description of the following, if the management approach includes that component:
i. Policies
ii. Commitments
iii. Goals and targets
iv. Responsibilities
v. Resources
vi. Grievance mechanisms
vii. Specific actions, such as processes, projects, programs and initiatives
Attracting, recruiting and selecting the right talent is crucial for the continued success of New Gold and to support our culture of empowering employees for exceptional performance. Our Human Resource teams work to ensure that the best and most qualified individuals are recruited for all available employment opportunities, and that the recruitment process is free from bias and discrimination.
103-3 Evaluation of the management approach For each material topic, the reporting organization shall report the following information: 
a. An explanation of how the organization evaluates the management approach, including:
i. the mechanisms for evaluating the effectiveness of the management approach;
ii. the results of the evaluation of the management approach;
iii. any related adjustments to the management approach
The community investment strategy is reviewed and validated on a bi-annual basis at each site by the Management team. Goals and targets are set at the beginning of each year, and reaching these goals is an indicator of success for each operation.
202-1

Ratios of standard entry level wage by gender compared to local minimum wage

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Disclosure Requirement Disclosure Response
a. When a significant proportion of employees are compensated based on wages subject to minimum wage rules, report the relevant ratio of the entry level wage to the minimum wage by gender at significant locations of operation No minimum used as a reference point.
b. When a significant proportion of other workers (excluding employees) performing the organization’s activities are compensated based on wages subject to minimum wage rules, describe the actions taken to determine whether these workers are paid above the minimum wage.

No minimum used as a reference point.
c. Whether a local minimum wage is absent or variable at significant locations of operation, by gender. In circumstances in which different minimums can be used as a reference, report which minimum wage is being used

No minimum used as a reference point.
d. The definition used for ‘significant locations of operation’
Region
Corporate The Corporate office of New Gold is located at 181 Bay Street, Suite 3320, Toronto, ON, M5J 2T3, core downtown Toronto area.
Blackwater There are two offices: Vancouver and Vanderhoof
New Afton The New Afton Mine office is located on site which is 10 km from the city of Kamloops in the interior region of British Columbia.
Rainy River The office is located in Thunder Bay, one office located in Emo, one warehouse in Fort Frances, and the Mine Site is located 30 minutes northeast of Emo, ON.
CSP The Cerro de San Pedro mine is located in the municipality of Cerro de San Pedro, in the state of San Luis Potosí, located in the central area of the state.

The municipality is located in the central area of the state. The coordinates of the municipal head are: 100º 48' west longitude and 22º 13' north latitude with a height of 2040 mesnm.

Its limits are: to the north and west with Soledad de Graciano Sánchez; to the east Armadillo de los Infante; to the south San Luis Potosí and Villa de Zaragoza.
202-2

Proportion of senior management hired from the local community

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Disclosure Requirement Disclosure Response
Is there a global policy or common practices for granting preference to local residents when hiring in significant locations of operations?
Region
Corporate No global policy or practice in place.
Blackwater N/A
New Afton Common practice is to focus on local residents for recruitment, no formal policy in place
Rainy River Common practice is to hire locals for entry level positions. For example, Labourers, assay lab tech, surface miners, etc. For professional roles we will look for locals first then go outside the area if we cannot find someone local.
CSP The policy treatment is the same to all employees. The objective of our policy is the employee's welfare to achieve the objectives of the company.
a. Percentage of senior management at significant locations of operation who are hired from the local community
Region
Corporate 80%
Blackwater N/A
New Afton 50%
Rainy River N/A
CSP 5%
b. The definition used for ‘senior management’
Region
Corporate Individuals at a high level of management. Roles in senior management position: Executive and GM's
Blackwater
New Afton
Rainy River
CSP

Indirect Economic Impacts

Disclosure Number Disclosure Title Disclosure Requirement Disclosure Response
103-1 Explanation of the material topic and its Boundary a. An explanation of why the topic is material New Gold recognizes that in the areas where we operate, our investments contribute greatly to the local and regional economies.
b. The Boundary for the material topic, which includes a description of:
i. where the impacts occur; 
ii. the organization’s involvement with the impacts. For example, whether the organization has caused or contributed to the impacts, or is directly linked to the impacts through its business relationships
New Gold contributes locally to indirect economic impacts through investments in education, health and arts & culture, the environment and social services at each of our operations. The boundary for this topic is limited to the communities, regions and countries we operate in.
c. Any specific limitation regarding the topic Boundary Regional impacts are not accounted for. Although regional impacts may not be known and quantified, New Gold's operations have direct and indirect regional economic impacts.
103-2 The management approach and its components a. An explanation of how the organization manages the topic New Gold believes in investing in local community programs that create indirect impact in the areas of education, health, social services, arts & culture, and the environment. Each operation manages a community investment fund that indirectly contributes to the local economies and communities in the areas of operation.
b. A statement of the purpose of the management approach New Gold promotes each operation managing a community investment fund in order to support sustainable community development initiatives that last beyond New Gold’s presence.
c. A description of the following, if the management approach includes that component:
i. Policies
ii. Commitments
iii. Goals and targets
iv. Responsibilities
v. Resources
vi. Grievance mechanisms
vii. Specific actions, such as processes, projects, programs and initiatives
Each operation develops a community investment strategy in accordance with the Community Engagement and Development Management Standard. The strategy is reviewed and revised on an annual basis to ensure the greatest impact is being had an each operation.
103-3 Evaluation of the management approach For each material topic, the reporting organization shall report the following information: 
a. An explanation of how the organization evaluates the management approach, including:
i. the mechanisms for evaluating the effectiveness of the management approach;
ii. the results of the evaluation of the management approach;
iii. any related adjustments to the management approach
The community investment strategy is reviewed and validated on a bi-annual basis at each site by the management team. Goals and targets are set at the beginning of each year, and reaching these goals is an indicator of success for each operation.
203-1

Infrastructure investments and services supported

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Disclosure Requirement New Afton Rainy River Cerro San Pedro
a. Extent of development of significant infrastructure investments and services supported No significant infrastructure was developed in 2019. Investments in: sewage system, roads, potable water, public lighting and house and church restoration in communities around mine site.
i. What was the extent of the development? Improved drainage and sewage system.

Improved pavements on main streets.

Improved potable water system and installation of new higher capacity storage tank.

Installation of public lighting to local communities using a renewable energy source (solar power system).

Restoration of houses near mine site.

Church restoration.
ii. What was the cost? 470,000 USD
iii. What was the duration? Throughout 2019
b. Current or expected impacts on communities and local economies, including positive and negative impacts where relevant Very positive impacts on communities due to improved living conditions and improved infrastructure support for tourism in the municipality.
c. Whether these investments and services are commercial, in-kind, or pro bono engagements Pro-bono engagement and legacy to the communities.

Procurement Practices

Disclosure Number Disclosure Title Disclosure Requirement Disclosure Response
103-1 Explanation of the material topic and its Boundary a. An explanation of why the topic is material This topic is material as the procurement of certain goods and services is essential to processes within New Gold operations. It also has a large impact for host communities.
b. The Boundary for the material topic, which includes a description of:
i. where the impacts occur; 
ii. the organization’s involvement with the impacts. For example, whether the organization has caused or contributed to the impacts, or is directly linked to the impacts through its business relationships.
The boundary for this topic is limited to the jurisidictions of our mining operations and corporate and regional offices.
c. Any specific limitation regarding the topic Boundary
103-2 The management approach and its components a. An explanation of how the organization manages the topic Formalized local procurement and business development programs are being developed at sites in an effort to maximize the shared economic benefits of local procurement practices.
b. A statement of the purpose of the management approach New Gold is committed to providing opportunities for communities associated with our operations and to sharing in the benefits which flow from our activities. The purpose of this management system is to fulfill said commitment.
c. A description of the following, if the management approach includes that component:
i. Policies
ii. Commitments
iii. Goals and targets
iv. Responsibilities
v. Resources
vi. Grievance mechanisms
vii. Specific actions, such as processes, projects, programs and initiatives
New Gold outlines procurement targets, policies and commitments in the Community Engagement and Development Management Standard (CEDMS) that is implemented at each site.

All employees of New Gold, including those responsible for procurement are bound by the company's Code of Business Conduct and Ethics
103-3 Evaluation of the management approach For each material topic, the reporting organization shall report the following information: 
a. An explanation of how the organization evaluates the management approach, including:
i. the mechanisms for evaluating the effectiveness of the management approach;
ii. the results of the evaluation of the management approach;
iii. any related adjustments to the management approach
New Gold outlines procurement targets, policies and commitments in the Community Engagement and Development Management Standard (CEDMS) that is implemented at each site. Each site is audited on the CEDMS on a three-year cycle – internally audited, peer audited, externally audited.
204-1

Proportion of spending on local suppliers

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Disclosure Requirement Rainy River New Afton
a. Percentage of the procurement budget used for significant locations of operation that is spent on suppliers local to that operation (such as percentage of products and services purchased locally)
i. Percentage of total procurement spent on local suppliers (community/local vendors) 23.50% 38.00%
ii. Percentage of total procurement spent on national vendors. 70.30% 23.00%
b. The organization’s geographical definition of ‘local’ Businesses in NW Ontario Business in Thompson Nicola Region
i. Where are the “local” suppliers located? What regions/villages/towns? Atikokan, Red Lake, Bawick, Stratton, Devlin, Emo, Rainy River, Morson, Bergland, Keewatin, Nestor Falls, Pawitik, Sioux Narrows, Rosslyn, Dryden, Fort Frances, Kenora Thompson Nicola Region, including Kamloops and surrounding towns within the region.
c. The definition used for ‘significant locations of operation’ Rainy River Mine New Afton Mine

Anti-Corruption

Disclosure Number Disclosure Title Disclosure Requirement Disclosure Response
103-1 Explanation of the material topic and its Boundary a. An explanation of why the topic is material New Gold ensures all directors, employees, contractors and representatives of the company adhere to New Gold's Anti-Bribery and Anti-Corruption Policy.
b. The Boundary for the material topic, which includes a description of:
i. where the impacts occur; 
ii. the organization’s involvement with the impacts. For example, whether the organization has caused or contributed to the impacts, or is directly linked to the impacts through its business relationships
New Gold ensures all directors, employees, contractors and representatives of the company adhere to New Gold's Anti-Bribery and Anti-Corruption Policy
c. Any specific limitation regarding the topic Boundary New Gold and supplier activities
103-2 The management approach and its components a. An explanation of how the organization manages the topic New Gold manages anti-corruption by ensuring all directors, employees, contractors, and representatives of the Company operate in alignment with the Code of Business Conduct and Ethics. Furthermore, the corporation requires all of the aforementioned participants to report violations of the Code of Business Conduct and Ethics.
b. A statement of the purpose of the management approach New Gold is committed to mitigating all corruption at all levels of company activity. 
c. A description of the following, if the management approach includes that component:
i. Policies
ii. Commitments
iii. Goals and targets
iv. Responsibilities
v. Resources
vi. Grievance mechanisms
vii. Specific actions, such as processes, projects, programs and initiatives
New Gold ensures all directors, employees, contractors and representatives of the company adhere to New Gold's Anti-Bribery and Anti-Corruption and Whistleblower Policies.
103-3 Evaluation of the management approach For each material topic, the reporting organization shall report the following information: 
a. An explanation of how the organization evaluates the management approach, including:
i. the mechanisms for evaluating the effectiveness of the management approach;
ii. the results of the evaluation of the management approach;
iii. any related adjustments to the management approach
New Gold actively monitors any inquiries made through its Legal department and the Whistleblower Hotline. There were no significant changes in 2019.
205-1

Operations assessed for risks related to corruption

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Disclosure Requirement Disclosure Response
a. Total number and percentage of operations assessed for risks related to corruption New Gold assesses risk associated with corruption at all levels of company activity.
b. Significant risks related to corruption identified through the risk assessment No significant risks associated with corruption have been identified.
205-2

Communication and training about anti-corruption policies and procedures

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Disclosure Requirement Disclosure Response
a. Total number and percentage of governance body members that the organization’s anti-corruption policies and procedures have been communicated to, broken down by region 100%
b. Total number and percentage of employees that the organization’s anti-corruption policies and procedures have been communicated to, broken down by employee category and region 100%
c. Total number and percentage of business partners that the organization’s anti-corruption policies and procedures have been communicated to, broken down by type of business partner and region. Describe if the organization’s anti-corruption policies and procedures have been communicated to any other persons or organizations 100%
d. Total number and percentage of governance body members that have received training on anti-corruption, broken down by region 0%
e. Total number and percentage of employees that have received training on anti-corruption, broken down by employee category and region 100%