CSA Staff Notice 51-333 Environmental Reporting Guidance
provides guidance on environmental matters that issuers should
consider when preparing their continuous disclosure documents. It
is intended to assist in determining what information about
environmental matters needs to be disclosed, and enhancing or
supplementing disclosure regarding environmental matters, as
necessary. The key disclosure requirements with respect to
environmental matters relate to: (i) environmental risks; (ii)
trends and uncertainties; (iii) environmental liabilities; (iv)
asset retirement obligations; and (v) financial and operational
effects of environmental protection requirements. For instance,
management's discussion and analysis ("MD&A")
should include a description of what has been, and is reasonably
likely to be, the impact of environmental trends or uncertainties
on revenues, expenditures and cash flows, and the impact these have
on the issuer's financial condition and liquidity (if any). In
addition, an issuer may have potential environmental liabilities
that are not reflected in the financial statements because their
long-term or contingent nature can make them particularly difficult
to quantify or because they are not individually material but,
together, may indicate an underlying risk or trend that could be
material in the long-term. As such, a discussion of material
potential environmental liabilities should be included in the
MD&A in order to help investors understand the nature of
potential liabilities, their likely timing and magnitude and the
probability of occurrence. An issuer should also assess whether,
due to the nature of its operations, it needs to describe
environmental risks in its continuous disclosure documents, such as
annual information forms. CSA Staff Notice 51-333 also provides a
number of other examples of disclosure with respect to
environmental matters which are not specifically included here that
issuers should consider when preparing their continuous disclosure
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
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