1a. The first phase of taxonomy development will focus on climate mitigation. In subsequent phases of the Canadian taxonomy, which objectives should be prioritized? Please select your top choices.

• Climate change adaptation / resilience
• Circular economy

2a. Do you agree or disagree with these proposed principles as the foundation for the taxonomy?

Agree

2b. Please share the reason for your answer in the space provided

Champion supports the six proposed principles and would highlight two considerations that are particularly relevant for Canadian mining issuers.

Interoperability. More than sixty jurisdictions are developing or have implemented taxonomies, and Canadian producers serving export markets are increasingly assessed against several of them simultaneously. Where a peer jurisdiction has already published criteria for an activity that also occurs in Canada, we would encourage the Institute to consider these criteria and align with those when possible, and to depart from them only where a Canadian-specific technical or geographic factor justifies it. Iron ore extraction is a good example, as it is already addressed in the Australian taxonomy.

Regional adaptation. The report correctly notes that low-carbon technologies that are viable in southern Canada may not be viable in northern or remote communities. This is a material consideration in the Labrador Trough, where extreme cold weather period, remoteness from major infrastructure including access to power sources, and equipment availability constrains the pace at which certain decarbonization measures can be deployed. However, it is worth mentioning that the Labrador Trough is one of Canada’s most developed mining regions and holds some of the purest iron ore in the world, now recognized on Canada’s Critical Minerals List for its strategic role in decarbonizing the steel industry. The Labrador Trough has tremendous long-term potential, supported by existing operations and development projects, and thanks to current access to clean hydroelectric power, high-purity iron ore concentrate produced in this region has one of the lowest carbon footprints in the world.

Since the restart of the Bloom Lake mine, Champion has invested over $2.5 billion across its various projects in the Labrador Trough in addition to 5B by its predecessors. We are proud to count the Government of Quebec among our shareholders and to have generated one of the strongest returns for Quebec taxpayers in recent years. Quebec’s cumulative investments of $62.5 million in Champion and its subsidiaries have generated a gain of approximately $348 million for Quebec taxpayers. In addition, our operations have contributed nearly $1 billion in taxes and royalties to the governments of Quebec and Canada.

3. Please rate each of the principles below on a scale from “very important” to “not at all important.”

Credible

Very important

Usable

Very important

Interoperable

Very important

Dynamic

Important

Regionally Specific

Very important

Prioritized

Important

4a. Do you agree or disagree with the proposed partial alignment approach, which would require entities to disclose the extent to which DNSH/MSS criteria are or are not met rather than requiring full alignment with all DNSH/MSS criteria?

Neutral

4b. Please explain your answer in the space below

We have no comment at this time.

5a. Do you agree or disagree with the proposed scope of objectives to be covered under the DNSH and MSS frameworks?

Neutral

5b. Please explain your answer in the space below

We have no comment at this time.

6a. Do you agree or disagree with the proposed approach to grounding the DNSH/MSS frameworks in Canadian legislation and going beyond existing laws and standards where necessary?

Neutral

6b. Please explain your answer in the space below

We have no comment at this time

7. In which areas, if any, is it necessary to go beyond existing laws and standards for the DNSH/MSS framework?

We have no comment at this time.

8a. Do you agree or disagree that different DNSH/MSS standards should apply to projects or entities of different sizes? E.g. more comprehensive disclosures required for larger projects and/or entities, with more streamlined disclosures for smaller projects and/or entities?

Neutral

8b. Please explain your answer in the space below

We have no comment at this time.

9. Are there any gaps in the proposed DNSH/MSS framework that could result in unintended environmental or social harms?

We have no comment at this time.

10. How should the taxonomy operationalize the principles of the UN Declaration on the Rights of Indigenous Peoples and, in particular, the principle of Free, Prior, and Informed Consent, in the MSS framework?

We have no comment at this time.

11. Is there any other feedback you would like to provide on the proposed MSS/DNSH framework?

We have no comment at this time.

12a. Do you agree or disagree with this approach?

Agree

12b. Please explain your answer in the space below

We support limiting the green category to zero and near-zero emissions activities and their direct enablers. Setting a high bar preserves the credibility of the label and avoids the dilution that occurs where higher-emitting activities qualify as green based on current benchmarks alone.

We would flag one consequence of Section 3.2 as drafted. Upstream activities are excluded from the green category unless they are zero or near-zero emissions or contribute exclusively to a climate solution and are otherwise assessed against the transition category. For high-purity iron ore, the contribution to a lower-emission outcome is neither incidental nor generic: ore of a sufficient grade and low contaminant content is a technical precondition for the DRI-EAF steelmaking route, which cannot operate on lower quality iron ore. In other words, the use of high-purity iron ore meets the requirements needed to eliminate the use of coal in steelmaking, reducing CO₂ emissions by 50% and by up to 85% when a clean fuel such as green hydrogen is used in the steelmaking process. We do not ask that the production of high-purity iron ore be treated as green, and we agree that assessment against the transition category is appropriate. We recommend that the sectoral criteria acknowledge this enabling relationship explicitly, rather than classifying high-purity iron ore alongside all other upstream inputs without distinction.

Champion Iron has demonstrated its ability to responsibly produce a world-class, high-purity iron ore concentrate: a critical mineral for the decarbonization of the steel industry, produced with one of the lowest carbon footprints in the world thanks to hydroelectric power. Our Direct reduction pellet feed (DRPF) project, which will enable us to produce some of the purest iron ore in the world at our Bloom Lake mine, and which represents a $500 million private investment, reflects our commitment to continue investing in the Labrador Trough, one of the world’s premier high-purity iron ore hubs, helping position Quebec and Canada as leaders in the decarbonization of the steel industry while making a meaningful contribution to the competitiveness of the critical minerals sector.

13a. Do you agree or disagree with this approach?

Agree

13b. Please explain your answer in the space below

Champion supports the proposed transition category and considers the guardrails, including the exclusion of dead-end pathways and of new high-emitting infrastructure where a cost-effective low-carbon alternative already exists, to be appropriate.

We recommend clarifying two points in the sectoral criteria.

First, footnote 25 indicates that where a whole economic activity qualifies as taxonomy-aligned, the transition category may apply to all capital expenditure, operating expenditure and revenue associated with that activity. We consider this distinction to be a key source of practical value in the framework and recommend that it be preserved clearly in the final guidance.

Second, the whole-of-activity pathway requires alignment of Scope 1 emissions with net-zero trajectories. Bloom Lake’s concentration plants source their energy primarily from renewable hydroelectric power, which means residual emissions are concentrated in mobile equipment rather than in purchased electricity. This is characteristic of mining operations connected to low-carbon grids, and it has a direct bearing on how criteria should be framed: the relevant question is the trajectory of direct emissions from those remaining sources. For mining operations connected to low-carbon grids, the relevant question is the trajectory of direct emissions from mobile equipment and processing. Accordingly, we recommend that the criteria be expressed as emissions intensity per tonne of product, with defined future tightening dates, rather than technology-prescriptive requirements. This approach is consistent with Section 4.4 and preserves recognition of equivalent performance.

14a. Do you agree or disagree that the proposed guardrails for the transition category (both for the whole-of-activity and measures pathways) are sufficient to protect the science-based credibility of the category and reduce the risk of carbon lock-in, while supporting usability?

Agree

14b. Please explain your answer in the space below

The guardrails are appropriate in substance. Excluding investments that lock activities into dead-end pathways, and requiring alignment with net-zero trajectories rather than merely demonstrating improvement over current performance, sets a higher standard than most transition labels internationally and strengthens the credibility of the framework.

Our comment concerns usability rather than adequacy. The concept of a dead-end pathway carries significant consequences for an issuer but is defined qualitatively and applying it to a specific investment decision will require judgment.

To enhance predictability and facilitate implementation, we recommend that the sectoral criteria set out how this assessment is to be made, including which technologies or configurations are considered dead-end for a given activity and at what point in time. This would allow issuers to assess eligibility with reasonable certainty before committing capital rather than after.

15a. Do you agree or disagree that the taxonomy should include a third “abatement” category, as proposed, that covers demand-decline activities?

Neutral

15b. Please explain your answer in the space below

We have no comment at this time.

16. Should any additional guardrails be considered?

We would suggest two additions.

First, a requirement for measurement and verification of the claimed reductions. Several of the illustrative guardrails address what is invested in, but not whether the expected reductions are subsequently confirmed. Post-investment verification against a defined baseline would strengthen credibility at modest cost.

Second, clarity on how the ring-fencing requirement is to be evidenced. The framework relies on funds being allocated exclusively to eligible measures, and the guidance should specify what documentation supports that claim, particularly where an issuer finances through general corporate facilities alongside use-of-proceeds instruments.

17. Is there any other feedback you would like to provide on the proposed activity classification framework?

One point relevant to sector scoping. The report identifies mining as a priority sector and describes it as critical minerals extraction. High-purity iron ore has been listed on Canada’s Critical Minerals List since June 2024 for its strategic role in decarbonizing the steel industry and is also listed by Quebec and by Newfoundland and Labrador. It is also important to note that investing in high-purity iron ore is very productive for Canadians. Historically, a dollar invested in high-purity iron ore production yields nine times more economic benefit than a dollar invested in an average Canadian industry, driven in large part by asset life: iron ore projects typically operate roughly a decade longer than other mining projects, spreading returns over a longer period..

Despite these advantages, a gap has emerged between Canada’s share of the global iron ore market and that of other major producing countries, such as Australia. While Australia’s iron ore resources are generally lower in quality, the country has invested heavily in its iron ore sector, generating approximately $20 billion annually in taxes and royalties over the past decade.

We recommend that the final report recognize explicitly that high-purity iron ore extraction is in scope. Steelmaking is identified in the framework as a transition activity, and the DRI-EAF route that enables its decarbonization depends on feedstock that only a small fraction of global iron ore suppliers can meet. Recognizing this enabling relationship would support a more coherent value-chain approach to the transition and align with broader efforts to strengthen and grow Canada’s low-carbon steel industry. It would also help ensure that capital can support the upstream investments necessary to enable decarbonization downstream

18a. Do you agree or disagree with the proposed approach for developing technical screening criteria?

Agree

18b. Please explain your answer in the space below

We support the proposed approach, particularly the preference for quantitative, outcome-based criteria and the commitment to benchmark against credible taxonomies in peer jurisdictions.

Two points on application.

First, interoperability should be treated as a core implementation principle. Where a peer jurisdiction has already published criteria for an activity that also occurs in Canada, those criteria could serve as a useful starting point, with any departures supported by specific technical, geographic or market considerations relevant to the Canadian context. Iron ore extraction is a good example, since it is already addressed in the Australian taxonomy and several companies, such as Champion are subject to reporting requirements in both jurisdictions.

Second, we also recommend that the principle of regional adaptation be meaningfully reflected in the mining criteria Operations in the Labrador Trough face cold climate, remoteness and equipment availability constraints that materially affect the pace at which certain measures can be deployed. Recognizing these realities through differentiated timelines or tiered thresholds would support practical implementation while maintaining the overall level of ambition.

19. Please rate each of the proposed elements for the screening criteria on a scale from “very important” to “not at all important.”

Forward-looking wherever possible

Very important

Include sunset and/or sunrise dates where relevant

Important

Revise as necessary during regular review periods

Important

Primarily use quantitative metrics

Very important

Primarily focus on Scope 1 emissions but address Scope 2 and 3 emissions where feasible and/or material

Very important

Informed by a range of robust methods

Important

20. When thinking about the taxonomy’s credibility and usability, how technologically specific or prescriptive should the technical screening criteria be?

Criteria should be performance-based rather than technology-prescriptive. Specifying an emissions intensity threshold per unit of production, with defined tightening dates, allows operators to reach the outcome through whatever combination of measures is technically and economically viable at their site. Prescribing technologies has the opposite effect: it favours a single pathway, fails to recognize equivalent performance achieved by other means, and dates quickly as technology evolves.

21. Do you agree or disagree with the proposed approach of focusing primarily on Scope 1 emissions, and addressing Scope 2 and 3 emissions where feasible and/or material?

Agree: Champion supports the proposed focus on Scope 1 emissions, with Scope 2 and Scope 3 addressed where feasible and material. We agree with the report’s observation that downstream Scope 3 emissions represent the majority of emissions associated with iron ore extraction, and that low-carbon solutions at the source of those emissions are at varying stages of technological development.

We would make one substantive recommendation. Where a producer supplies ore of a grade and chemistry suitable for direct reduction, the product itself is a downstream emissions reduction lever, because it enables a steelmaking route with materially lower emissions than the blast furnace route.Assessed on a downstream Scope 3 basis, high-purity iron ore enables lower emission steelmaking compared to iron ore that can only be processed through the blast furnace route. Additionally, such high purity iron ore quality is scarce globally and positions Canada as a potential strategic supplier to many trade partners seeking to decarbonize their steelmaking industry. Australian criteria recognize this by requiring, after 1 January 2030, that entities demonstrate through offtake arrangements or other means that ore is destined for direct reduced iron or a better-performing low-emission process. We recommend that Canadian criteria adopt an equivalent approach, including the transition period, which allows time for traceability and contracting practices to mature.

22. Overall, how satisfied are you with the proposed sustainable finance taxonomy framework?

Neutral

23. Is there any other feedback you would like to provide on the methodology report as a whole that has not already been covered?

The proposed framework provides a strong foundation. However, further clarity on whether high-purity iron ore extraction falls within the scope of the sectoral criteria would be valuable, as this question remains unresolved in the current draft and is relevant to the broader high-purity iron and steel value chain.

Two closing points.

First, on scope. We recommend that the final report explicitly recognizes the role of high-purity iron ore extraction within the mining priority sector. High-purity iron ore has been included on Canada’s Critical Minerals List since June 2024 because of its importance to low-emission steelmaking and is also recognized as a critical mineral by Quebec and Newfoundland and Labrador. The framework identifies steelmaking as a transition activity, and the DRI-EAF route that underpins its decarbonization depends on feedstock that only a small fraction of global iron ore supply can provide. Canada is uniquely positioned in this regard, with one of the world’s purest hubs of high-purity iron ore in the Labrador Trough. Explicit recognition of this enabling relationship would support a coherent value-chain approach to decarbonization, help align the framework with Canada’s broader objective of growing a competitive low-carbon steel industry, and provide greater certainty for investments across the iron and steel value chain.

Second, on process. Champion would welcome the opportunity to contribute operational and technical expertise through the mining sector technical working group during the development of the 2027 criteria. Practical input from operators can help ensure that the criteria remain both ambitious and implementable across Canada’s diverse mining regions.

More broadly, the taxonomy represents an opportunity to reinforce Canada's position in the emerging low-carbon steel value chain. Coupled with strategic infrastructure investments and the continued development of critical mineral corridors such as the Labrador Trough, a clear and predictable framework can help attract investment, strengthen supply chain resilience, expand export opportunities and support long-term economic growth.