Cambridge Bay Tkaluktutiak ANA Kugluktuk sgh ee Bathurst Inlet Kingaok spsLbe Bay Chimo Umingmaktok Dro» Gjoa Haven Okhoktok pose ‘Taloyoak Cong Kugaaruk dln P.O. Box 18 Cambridge Bay, NU XOB 0CO “Telephone: (867) 983-2458 Fax: (867) 983-2701 ‘www kitasea August 24, 2016 Tineka Simmons Senior Project Manager Norther Projects Management Office Canadian Northern Economic Development Agency Dear Ms. Simmons: RE: Nunavut Impact Review Board June 15, 2016 Hearing Report (Report) - Sabina Gold & Silver Corp.’s (Sabina) Back River Gold Mine Project (the Project) ‘The Kitikmeot Inuit Association (KIA) was an active participant throughout the ‘Nunavut Impact Review Board’s (NIRB or the Board) review of the Project. KIA is in receipt of correspondence to NIRB from Sabina dated July 20, 2016 requesting that the June 15, 2016 NIRB Report be returned to the Board under one of paragraphs 12.5.7(4) or ¢) of the Nunavut Land Claims Agreement (NLCA). KIA is the Designated Inuit Organization under Articles 6, 19, 20, 21, 26 and 27.2 of the NLCA in relation to the Project. KIA is also the landowner of a majority of the and upon which the Project will be constructed, and representative of the socio- economic interest for Inuit of the Kitikmeot Region. KIA has always encouraged responsible mining development in the Kitikmeot Region and has supported Sabina and its plans for the Project accordingly. However, you should be aware that final KIA support for the Project is contingent on the completion of an Inuit Impact Benefit Agreement (IBA), land tenure agreement, and the Board’s inclusion of the commitments, terms and conditions, jointly developed by KIA and Sabina, in any eventual Project Certificate. Inuit support for the Project is firm across the Kitikmeot Region, as indicated by the results of Sabina’s recent community consultation tour, Notwithstanding, due to the Board’s June 15, 2016, recommendation for the Project not to proceed at this time, KIA is unable to effectively determine if or to what extent the section 35 rights (Rights) of the Kitikmeot Inuit have been addressed. ‘Through KIA’s active participation in the NIRB review process commitments, terms and conditions (Terms) for inclusion in the eventual Project Certificate were developed jointly with Sabina to satisfy KIA’s concems should the project proceed as proposed. The NIRB Report did not specifically address or consider these Terms, and as such KIA cannot determine if our Section 35 Rights have been fully accommodated at this time. Affiliates: Nunavut Tunngavik Incorporated, Kitikmeot Corporation, Nunavut Resources Comporation,P.O. Box 18 Cambridge Bay, NU XOB 0CO Telephone: (867) 983-2458, Fas: (667) 983-2701 sw kitacea In these circumstances, in light of KIA’s review of the Report and Sabina’s submissions to NIRB, we are of the view that additional discussion is required. While KIA agrees with Sabina that the report should be returned to NIRB under section 12.5.7 of the NLCA, we think that the Board should be given the discretion to determine how best to structure any further review. It is only once a definitive and final decision is reached on the Project that KIA can fully assess whether our Section 35 Rights have been adequately addressed. Yours truly, seth President -Kitikmeot Inuit Association e Aiites: Nunavut Tunngavik Incorporated, Kitikmeot Corporation, ‘Nunavut Resources Corporation