The Canadian Action arises out of litigation that was brought before the Guatemalan courts in May 2017 by CALAS, a Guatemalan non-profit organization, concerning Tahoe’s Escobal mining project in Guatemala. The Canadian Action asserts that a press release issued by Tahoe on May 24, 2017 did not provide adequate disclosure about the CALAS litigation, including the risk of a suspension of the exploitation license for the Escobal mine arising from the CALAS litigation. On July 5, 2017, Tahoe disclosed that the Supreme Court of Guatemala had provisionally suspended Tahoe’s exploitation license. It is alleged that, because of the misrepresentations, Canadian Class Members paid too much when they acquired Tahoe’s securities during the Class Period and suffered damages after the alleged misrepresentations were publicly corrected on July 5, 2017.

Canadian Class Members include: All persons and entities, wherever they may reside or be domiciled, who acquired securities of Tahoe during the period from and including May 24, 2017 to and including July 5, 2017 (“Class Period”) on any Canadian exchange (including, without limitation, the Toronto Stock Exchange) or any Canadian alternative trading system, or on any exchange or trading platform outside Canada and the United States, other than certain “Excluded Persons”. You are presumed to be a Canadian Class Member if you purchased Tahoe shares during this period (May 24, 2017 to and including July 5, 2017) and your trading records have the ticker symbol “THO” for those purchases.

On behalf of the Canadian Class, the Canadian Action asserts claims under Part XXIII.1 of Ontario’s Securities Act and, if necessary, the equivalent provisions of the securities legislation of other provinces. Additionally, the Canadian Action advances claims in common law negligent misrepresentation.

A settlement of the Canadian Action has been reached. If you are a Canadian Class Member, you can make a claim for compensation following the instructions at “5. How can I receive a payment?” below.

A separate settlement (“U.S. Settlement”) has been reached concurrently in the securities class action in the United States District Court, District of Nevada (“U.S. Action”) on behalf of persons who purchased or otherwise acquired Tahoe’s common stock in the United States or on the New York Stock Exchange between April 3, 2013 and August 24, 2017, inclusive (“U.S. Class” and “U.S. Class Members”). You are presumed to be a U.S. Class Member if you purchased Tahoe common stock during this period and your trading records have the ticker symbol “TAHO” for those purchases.

If you qualify as both a U.S. Class Member and a Canadian Class Member, you must submit a claim for compensation from the settlement of the Canadian Action in respect of all purchases or acquisitions that qualify you as a Canadian Class Member, and you must separately submit a claim for compensation from the settlement of the U.S. Action in respect of all purchases or acquisitions that qualify you as a U.S. Class Member. You will only receive compensation from the settlement fund for the Canadian Settlement in respect of purchases or acquisitions that qualify you as a Canadian Class Member. Likewise, you will only receive compensation from the settlement fund for the U.S. Settlement in respect of purchases or acquisitions that qualify you as a U.S. Class Member.

U.S. Class Members should go to www.USTahoeSettlement.com for important details on the U.S. Settlement, including how to submit a claim for compensation from the U.S. Settlement.

On May 25, 2023, the Canadian Plaintiff, Defendants and the parties to the U.S. Action executed a Settlement Agreement (“Settlement Agreement”), which is subject to approval by the Canadian Court and U.S. Court. The Settlement Agreement provides for the payment of US$13,500,000 (“Canadian Settlement Amount”) in consideration of the full and final settlement of the claims of Canadian Class Members. All legal fees, the Funder’s commission, taxes and administrative expenses will be paid out of the Canadian Settlement Amount.

The Settlement Agreement provides that if approved by the Canadian Court and U.S. Court, the claims of Canadian Class Members (who do not opt out) asserted or that could have been asserted in the Canadian Action will be fully and finally released, and the Canadian Action will be dismissed.

The Settlement Agreement is not an admission of liability, wrongdoing, or fault on the part of the Defendants, all of whom have denied, and continue to deny, the allegations against them.

Under the Settlement Agreement, Tahoe and the other defendants to the U.S. Action have also agreed to pay a separate settlement amount of US$19,500,000 to resolve the claims of U.S. Class Members in the U.S. Action. The U.S. Settlement is being administered separately. U.S. Class Members are not entitled to make a claim for benefits from the Canadian Settlement in respect of purchases or acquisitions that qualify them as U.S. Class Members. U.S. Class Members should go to www.USTahoeSettlement.com for important details on the U.S. Settlement, including how to submit a claim for compensation from the U.S. Settlement.

Click here for important documents about the Settlements.

The Ontario Superior Court of Justice provided its authorization for notice be sent to potential members of the Canadian Class. You may have purchased or otherwise acquired shares of Tahoe Resources inc. between May 24, 2017 and July 5, 2017 on a Canadian stock exchange or trading platform, or any exchange or trading platform outside Canada and the United States, which would make you a member of the Canadian Settlement Class (a.k.a. Canadian Settlement Class Member).

Click here for the Long Form Notice to Canadian Settlement Class Members.

The only way to receive compensation from the Settlement is to submit a Claim. Claim Forms must be submitted by no later than January 3, 2024.

Click here to submit your claim online. It’s fast, easy and secure.

If you are not a member of the Canadian Settlement Class, you may be a member of the “U.S. Class”, which means that you are in the wrong website. U.S. Class Members should go to www.USTahoeSettlement.com for important details on the U.S. Settlement, including how to submit a claim for compensation from the U.S. Settlement.

Yes. There are some individuals and entities who are excluded by definition from recovering from the Settlements.

The following are Excluded Persons:

Excluded Persons” means the Defendants, and Tahoe’s and Pan American Silver’s past and present subsidiaries, affiliates, officers, directors, senior employees, partners, legal representatives, heirs, predecessors, successors and assigns, and any member of Clayton’s family; and any Person who or which timely and validly seeks exclusion from the Canadian Settlement Class in accordance with this Order.

To be eligible to receive a payment, eligible Canadian Claimants must submit a Claim Form, including the required supporting documentation, to the Canadian Claims Administrator no later than January 3, 2024, and their claim must satisfy the criteria set out Canadian Plan of Allocation that can be found here.

You can submit your Claim Form online:

Click here to review and complete the Online Claim Form - it’s fast, easy and secure. Your Claim must be submitted no later than January 3, 2024.

Please contact the Claims Administrator if you would like to request that a Claim Form be sent to you by mail, email or fax.

Separate Claim Forms should be submitted for each legal entity. For example, a claim submission from joint beneficial owners should include only the transactions of the joint beneficial owners, and not include any separate transactions of just one (1) of the joint owners. Conversely, a single Claim Form should be submitted on behalf of each individual owner and include all transactions made by that owner on one (1) Claim Form, no matter how many separate accounts that owner has (e.g., an individual shareholder with multiple accounts should include all transactions made in all accounts on one (1) Claim Form).

Please note: Separate Claim Forms should be submitted for each legal entity. For example, a Trust account or Retirement account are separate entities from an Individual account. Therefore, each account that is a separate legal entity should be submitted as its own claim.

One (1) Claim Form must be submitted for the joint account. Once the claim processing is complete, and if the claim is approved, the payment may be requested to be split into two. Documentation such as a separation agreement must be submitted to show the agreement made between the joint beneficial owners (i.e., each entitled to 50%).

An individual claim submitted by an individual or entity on their own behalf, or on behalf of others such as estates, executors, administrators, guardians, and trustees, should provide the following information.

Any documentation provided must include the claimant's name, account number and address.

Appropriate documentation to support your claim includes:

• Trade Confirmation - Trade confirmation slips showing the trade date, quantity, price per security and net amount of the transaction are acceptable forms of documentation to support your purchases and/or sales.

• Official monthly, quarterly or other periodic broker statements - Monthly, quarterly or other periodic statements provided by your broker listing your transactions are sufficient to prove purchase and sale transactions so long as the necessary information for that transaction is included, such as the trade date, quantity and price paid or received for each security, and the total amount paid or received for each transaction. These statements may also be used to support the quantity of securities held after the class period has ended, if such section is provided in the document. On your claim form, these will be listed as Beginning Holdings and Ending Holdings.

• Official authorized broker generated statements.

Please Note: The Claims Administrator, Class Counsel or the Court reserve the right to request additional information or documentation.

Spreadsheets, charts, tax forms, handwritten information, and other documentation prepared by the claimant are not considered adequate supporting documentation.

In the event that an individual claimant is deceased, the executor or representative of the estate may submit a Claim Form on their behalf and must also:

1. Duly complete and sign the Claim Form - must provide their name in Section II of the Claim Form;
2. Submit a copy of the death certificate; and
3. Submit a copy of the will, which indicates who the executor or representative of the estate is.

Other authorized representatives of an individual claimant, including guardians, conservators, and trustees must also:

1. Duly complete and sign the Claim Form - must provide their name in Section II of the Claim Form;
2. Submit valid proof of authority to file and sign claims on behalf of the claimant, stating the authorized representative’s titles or capacities. The telephone number of the beneficial owner may be used in verifying the claim.

Important: If such documents are not in your possession, please obtain copies or equivalent contemporaneous documents from your broker. Failure to supply this documentation could delay verification of your claim and could result in rejection of your claim.

Do not send original documents. Please keep a copy of all documents that you send to the Claims Administrator.

Nominee Claim Submissions

Click here for the Nominee page.

If you are a Nominee, you must provide the following five (5) documents:

1. DULY COMPLETED MASTER CLAIM FORM

• You must submit one (1) master Claim Form per submission. Your submission may contain one or more accounts.

• You must complete the Claimant Identification section, (Section II on page 4) and the Acknowledgements section (Section IV on page 6). The Claimant Identification Page must contain your institution contact information. The Acknowledgements Page must be signed by an authorized signatory who is listed in your signature verification document and must state the capacity (job) of the signatory.

2. SIGNATURE VERIFICATION DOCUMENT

• If you are an institution or claim preparer filing on behalf of client/customer or proprietary accounts (i.e., not an individual claimant), you must provide a document verifying that the individual who signed the Claim Form and any supplemental documents is authorized to sign on behalf of his/her company.

• Some common types of documents that fulfill this requirement include the following. (Please note that some entities may have different documents that fulfill this requirement. If you cannot submit the documents listed below, you must submit an equivalent document):

  • Copy of company's By-Laws, including signature page(s)

  • Copy of company's Corporate Resolution, including signature page(s)

  • Notarized affidavit signed by an officer of the institution clearly granting a specific individual(s) authorization or confirming his/her authority to sign on behalf of his/her company.

3. DATA VERIFICATION DOCUMENT(S)

• If you are an institution or claim preparer filing on behalf of client/customer or proprietary accounts (i.e. not an individual claimant), you must provide a notarized affidavit or signed letter on firm letterhead which meets the below criteria:
• Confirms the number of distinct accounts and transactions on your file
• Discloses the source of your data (i.e. internal data retention system)
• Attests to the truth and accuracy of the transactions and holdings on your electronic file
• Is executed by an authorized signatory who is listed on your signature verification document, and specifies both the capacity and contact information of that signatory.

4. AUTHORIZATION DOCUMENT (IF FILING ON BEHALF OF CLIENT OR CUSTOMER ACCOUNTS)

• If you are an institution or claim preparer filing on behalf of client/customer accounts (i.e. not an individual claimant), you must provide a current document verifying that you are authorized to file and sign claims on behalf of your clients.
• Some common types of documents that fulfill this requirement include the following:
• Power of Attorney
• Service Agreement
• Signed/dated letter on client's company letterhead specifically granting your company authority to file/sign claims on their behalf.
• Notarized affidavit or signed letter on your company's letterhead confirming your authority to file and sign claims on behalf of your clients. It must be executed by an officer of the company who is also listed on your signature verification document and reference the capacity and contact information of the signatory.

Please note that some entities may have different documents that fulfill this requirement. If you cannot submit the documents listed below, you MUST submit an equivalent document.

5. EXCEL SPREADSHEET CONTAINING TRANSACTIONS AND HOLDINGS

You must provide all transactions and holding amounts for each account you are filing for by following the required format set out in the Electronic Filing Instructions.

Click here to download the Electronic Filing Instructions.

Click here to download the Microsoft Excel Preformatted Spreadsheet for submitting your transactions.

ADDITIONAL DOCUMENTATION (IF REQUESTED) - DATA INTEGRITY AUDIT

The Claims Administrator may request that certain entities, as designated by Epiq, which submit claims electronically provide additional documentation to support certain transactions and/or holdings in the claims. This data integrity audit is designed to verify the overall integrity of a data submission. Accordingly, the documentation provided must be independent in nature and sufficient to verify the validity and accuracy of the entire data submission. Even if you provided a letter/affidavit attesting to the truth and accuracy of your data when initially submitting your claim electronically, we will require specific documentary evidence (trade confirmations, monthly statement, or equivalent), to independently verify the details of the transactions and/or holdings requested, if your claim is selected for a data integrity audit.

If you are filing a claim on behalf of an individual or joint account owners:

Some common types of documents that fulfill this requirement include the following:

• Copy of a Retainer Agreement;
• Copy of a Power of Attorney; or
• Signed letter from the Beneficial Owner(s)

If you are filing a claim on behalf of any other business or legal entity:

Some common types of documents that fulfill this requirement include the following:

• Copy of company's By-Laws, including signature page(s)
• Copy of company's Corporate Resolution, including signature page(s)
• Copy of the Articles of Incorporation
• Signed letter on the company’s letterhead by an officer of the filing institution or company clearly granting you authorization to file/sign on behalf of the company

The nine-digit, alphanumeric CUSIP number that is used to identify Tahoe common stock is 873868103. You are presumed to be a Canadian Class Member if you purchased Tahoe shares during this period and your trading records have the ticker symbol “THO” for those purchases.

P means Purchase - When you purchased your shares - There is a price associated with the transaction.

R means Receipt - A transfer of shares into an account. Generally, if you did not pay money for the received shares that were transferred, they should be considered transferred shares (a transfer in).

S means Sale - When the shares are sold or disposed of – There is a price associated with the transaction.

D means Delivery - A transfer of shares out of an account. Generally, if you did not receive money for the delivered shares, they should be considered transferred shares (a transfer out).

Use the account number for the account where the shares were purchased (should match the documentation that you are submitting).

Please note: you must file one (1) claim per beneficial owner, regardless of the number of accounts.

Yes. Brokerage commissions must be included in the total purchase amount and total sales proceeds.

Yes, you will be notified if your claim is deficient or rejected to give you an opportunity to remedy any deficiency in the completion of a Claim Form. The Claims Administrator may request and require via email or mail, if an email address is not available, that additional information be submitted by a claimant by a certain deadline.

Any person who does not respond to such a request for information within the required time period will be barred from receiving any payments pursuant to the Settlements.