McEwen Mining : 2023 Modern Slavery Report

MCEWEN MINING INC.

REPORT PURSUANT TO THE FIGHTING AGAINST FORCED LABOUR AND CHILD LABOUR IN

SUPPLY CHAINS ACT (CANADA) FOR THE YEAR 2023

1. Introduction

This report (the "Report") is produced by McEwen Mining Inc., and its subsidiaries, including 10393444 Canada Inc. ("McEwen" or the "Company") for the financial year starting January 1, 2023 and ending December 31, 2023 (the "Reporting Period") and sets out the steps taken by McEwen to prevent and reduce the risk that forced labour or child labour is used at any step of the production of goods in Canada or elsewhere or of goods imported into Canada by the Corporation.

This Report constitutes the first report prepared by the Corporation pursuant to Canada's new Fighting Against Forced Labour and Child Labour in Supply Chains Act (the "Act").

2. Steps to prevent and reduce risks of forced labour and child labour

We consider the respect of human rights to be a fundamental corporate responsibility and align our practices with international human rights standards. We place high importance on respecting human rights at all of our operations and expect the same of our business partners.

During the Reporting Period, we conducted a preliminary internal assessment of the risk that forced labour and/or child labour is present in our supply chain and reviewed our Supplier Code of Conduct in one of our operating entities.

Details of the above actions are set out in this Report.

3. Structure, activities and supply chains

McEwen is a US-based gold mining company focused on operating, developing, exploring and acquiring gold and copper properties in North and South America. McEwen Mining Inc. shares are listed on the New York Stock Exchange and the Toronto Stock Exchange.

We have two operating mining properties: the Fox Complex in Ontario, Canada (held by 10393444 Canada Inc.), and the Gold Bar Mine in Nevada, United States. We also own the Fenix Project, a development project in Sinaloa, Mexico. We also have a 49% joint venture in the operating San Jose Mine, operated by Hochschild Mining plc in Santa Cruz, Argentina and own 47.7% of the Los Azules advanced exploration project in San Juan, Argentina. We have other mining exploration interests in Canada, the United States, Mexico and Argentina, which are owned (directly or indirectly) by McEwen.

Our principal product is gold. Our Fox Complex and Gold Bar Mine produce gold doré bars. All gold doré produced is processed at refining facilities in Canada and the United States.

During the Reporting Period, the Fox Complex produced 44,450 ounces of gold, the Gold Bar mine produced 43,700 ounces of gold and the Fenix Project produced 800 ounces of gold.

McEwen conducted business with approximately 1,000 suppliers at the end of the Reporting Period. Our relationships with suppliers vary from one-off engagements through to long term contractual agreements. We source a diverse range of goods and services through our global supply chain. The primary categories of goods and services purchased include: support services equipment consumables, tools and spare parts; utilities; chemicals; and general industrials. Over ninety-nine percent of our suppliers come from the United States, Canada, and Mexico.

4. Policies, Governance and Due Diligence processes

McEwen is committed to embedding human rights considerations into its policies, governance framework and decision making. As such, McEwen sees the management of environmental, social and governance ("ESG") risks and opportunities as an inherent part of McEwen's success. McEwen regularly tracks the potential sustainability-related risks that are shaping its operating environment and develops and implements strategies to progress its performance across sustainability areas. McEwen Mining Inc.'s board of directors (the "Board of Directors") has delegated to its Environmental, Health and Safety Committee oversight of polices, practices and systems for effective management of corporate responsibility matters, including safety, health, environment and social performance. McEwen Mining Inc.'s Audit Committee monitors and ensures compliance with the Corporation's Code of Business Conduct and Ethics.

4.1. Supplier Due Diligence

During the Reporting Period, the Corporation conducted a risk analysis by screening major suppliers totalling over 55% of our annual spend. After completing this due diligence, we found no material risk of the presence of forced labour or child labour within our supply chain.

4.2. Code of Business Conduct and Ethics

McEwen's Code of Business Conduct and Ethics applies to all its constituencies, including the Board of Directors, management, and employees, in all of its operations. It addresses ethical conduct in our work environment, business practices and relationships with external stakeholders. The principles set out in the Code of Business Conduct and Ethics reflect McEwen's belief that honesty, fairness and integrity are integral to its business and the interests of its stakeholders. The Code of Business Conduct and Ethics details the standards of behaviour expected from all McEwen's representatives in their daily activities and in dealings with others.

Among other things, our Code of Business Conduct and Ethics requires compliance with laws and regulations in all of the jurisdictions in which McEwen operates. McEwen's Code of Business Conduct and Ethics can be found here: https://www.mcewenmining.com/investor- relations/corporate-governance/.

4.3. Complaint Procedure

In accordance with our Code of Business Conduct and Ethics, and our Anonymous Reporting Hotline procedures on our website (https://www.mcewenmining.com/investor-relations/corporate- governance/), should employees or suppliers have concerns regarding forced labour or child labour, or other matters, they have a responsibility to report their suspicions without fear of retaliation of any kind. To that effect, McEwen provides multiple channels for them to report any potential breach, on

a confidential basis or not. The Anonymous Reporting Hotline is a service accessible at any time, which is operated by an independent third-party service provider and can be accessed via phone, internet or mail. All submissions through the Compliance Hotline are then reviewed by McEwen's legal team and Board of Directors.

5. Assessing and managing our risk

McEwen uses a risk-based approach to assess and manage the risk of forced labour and child labour being utilized in its supply chain. Our approach helps us prioritize our efforts and adjust our actions. To date, the due diligence conducted by McEwen has not identified a material risk within our supply chain regarding the presence of forced labour or child labour.

6. Remediation Measures

Our Code of Business Conduct and Ethics and Anonymous Reporting Hotline procedures offer a reporting mechanism for our employees and suppliers to report ethical or legal violations, among other concerns. In accordance with our policies, if a situation of non-compliance is identified, McEwen will investigate and work to develop and implement a corrective plan to improve and remedy the situation if required. To date, McEwen has not identified any material risk of the presence of forced labour or child labour used in its activities or supply chain and therefore has not undertaken any measures to: (i) remediate forced labour or child labour in its activities and supply chain; or (ii) remediate loss of income that results from any measure taken to eliminate the use of forced labour or child labour in its activities and supply chain.

7. Training

All new office employees are assigned a mandatory onboarding package which includes our Code of Business Conduct and Ethics, which they are required to sign. During the Reporting Period, McEwen provided training to targeted audiences concerning human rights and the Act which addressed forced labour and child labour.

8. Assessing effectiveness

McEwen has in place a number of measures to identify, prevent and reduce the risk that forced labour or child labour is used in our activities and supply chain. While we have not yet taken any actions to assess the effectiveness of those actions, McEwen intends to assess its effectiveness in preventing and reducing risks of forced labour and child labour in its activities and supply chain at a later stage.

9. Forward Looking Information

This report contains certain forward-looking statements and information, including "forward-looking statements" within the meaning of the Private Securities Litigation Reform Act of 1995. The forward- looking statements and information expressed, as at the date of this report, McEwen Mining Inc.'s estimates, forecasts, projections, expectations or beliefs as to future events and results. Forward- looking statements and information are necessarily based upon a number of estimates and assumptions that, while considered reasonable by management, are inherently subject to significant business, economic and competitive uncertainties, risks and contingencies, and there can be no assurance that such statements and information will prove to be accurate. Therefore, actual results and future events could differ materially from those anticipated in such statements and information.

Risks and uncertainties that could cause results or future events to differ materially from current expectations expressed or implied by the forward looking statements and information include, but are not limited to, fluctuations in the market price of precious metals, mining industry risks, political, economic, social and security risks associated with foreign operations, the ability of the corporation to receive or receive in a timely manner permits or other approvals required in connection with operations, risks associated with the construction of mining operations and commencement of production and the projected costs thereof, risks related to litigation, the state of the capital markets, environmental risks and hazards, uncertainty as to calculation of mineral resources and reserves, and other risks. Readers should not place undue reliance on forward-looking statements or information included herein, which speak only as of the date hereof. The Company undertakes no obligation to reissue or update forward-looking statements or information as a result of new information or events after the date hereof except as may be required by law. See McEwen Mining's Annual Report on Form 10-K for the fiscal year ended December 31, 2023, and other filings with the Securities and Exchange Commission, under the caption "Risk Factors", for additional information on risks, uncertainties and other factors relating to the forward-looking statements and information regarding the Company. All forward-looking statements and information made in this report are qualified by this cautionary statement.

10. Approval and Attestation

This Report was approved pursuant to subparagraph 11(4)(b)(ii) of the Act by the Board of Directors of McEwen Mining Inc. In my capacity as an Officer of McEwen Mining Inc., and not in my personal capacity, I make this attestation in accordance with the requirements of the Act.

In accordance with the requirements of the Act, and in particular section 11 thereof, I attest that I have reviewed the information contained in the Report for the entities listed above. Based on my knowledge, and having exercised reasonable diligence, I attest that the information in the Report is true, accurate and complete in all material respects for the purposes of the Act, for the Reporting Period.

I have the authority to bind McEwen Mining Inc.

Per:

____________________________

Full Name: Perry Y. Ing

Date: May 30, 2024