Compliance posture
The four things that quietly kill businesses like this.
None of them are glamorous. All of them surface in a client's procurement review at year three, which is exactly when a services business can least afford to lose a contract.
1. Reporting codes
The line we do not cross.
The moment our work is used in a public disclosure by a listed company, it enters the world of JORC, NI 43-101, SAMREC, PERC or S-K 1300, and a Competent or Qualified Person must take responsibility for it.
Our operating rules
- Every deliverable is marked as decision-support material, not a Public Report.
- We never state or imply a tonnage, grade, or Exploration Target quantity. This is a bright line. Crossing it once creates securities-law exposure for us and for the client.
- A registered geologist co-signs — as a paid add-on — anything a client intends to disclose publicly.
- Every input, weighting and version is logged. If a client's disclosure is ever queried, the file is what protects both of us.
Why a mining engineer, and what that means
Firstpass is founded by a mining engineer, not a geologist. Under NI 43-101 a Qualified Person needs a relevant degree, membership of a recognised professional association, and at least five years of experience relevant to the specific subject matter — and QPs are explicitly not interchangeable across deposit types. JORC applies the same five-year test.
So we say it first, in writing, rather than hoping nobody asks. The engineering background is why the mineability screen exists and why no competitor at this price sells one. The geological sign-off comes from the expert network below.
2. Where we may practise
The technology-enabled expert network.
In every Canadian province and territory except Quebec, a business undertaking geoscience work must itself register and hold a Certificate of Authorization or Permit to Practice. That is a real, enforceable barrier for a foreign firm — and pretending otherwise would be the kind of thing that ends a company.
So Canada is not served directly. It is served through a network of locally registered professionals who hold the permit and contract with the client, while Firstpass supplies the technology, the archive and the analysis. The platform enforces this: a review cannot be assigned in a jurisdiction that requires a permit unless a permit number is on file for that reviewer.
| Jurisdiction | Practice licence required? | Reporting code | How we engage |
|---|---|---|---|
| Western Australia | No | JORC 2012 | Direct engagement |
| South Australia | No | JORC 2012 | Direct engagement |
| Northern Territory | No | JORC 2012 | Direct engagement |
| New South Wales | No | JORC 2012 | Direct engagement |
| Queensland | No | JORC 2012 | Direct engagement |
| Victoria | No | JORC 2012 | Direct engagement |
| Quebec | No | NI 43-101 | Expert network partner contracts with the client |
| Canada (other provinces and territories) | Yes — firm permit | NI 43-101 | Expert network partner contracts with the client |
Western Australia is the beachhead precisely because geoscience is not a licensed profession in Australia and the public data is the best on earth.
3. Data licensing
The register that is worth more than a year of revenue at diligence.
| Dataset | Commercial use | Redistribution | How we handle it |
|---|---|---|---|
| Copernicus Sentinel-1 and Sentinel-2 | Permitted — free, full and open | Permitted with attribution | Attribution carried on every deliverable: "Contains modified Copernicus Sentinel data". |
| Landsat, ASTER, SRTM (USGS / NASA) | Permitted — US public domain | Permitted | Attributed as a matter of practice. |
| EMIT, EnMAP, PRISMA hyperspectral | Permitted, terms differ per agency | Varies | Each agency licence read and recorded before first commercial use; registration completed where required. |
| Government geophysics and geology (AU) | Permitted — CC BY 4.0 | Permitted with attribution | Licence recorded per dataset in the register. |
| WDPA / Protected Planet | NOT permitted without written permission | Prohibited | Not used. Replaced with openly-licensed national protected-area datasets, which are higher resolution anyway. |
| Google Earth Engine | Free tier is noncommercial only | n/a | Commercial project on the usage-based Limited plan from day one, at a few dollars per job. |
| OpenStreetMap | Permitted under ODbL | Share-alike applies to derived databases | Used for context and visualisation; advice taken before embedding in a subscription product. |
| Mining cadastre portals | Public data, permitted | Check per portal | Official REST and WFS services only. Never an unauthorised scrape, never a login-gated bulk file. |
Two of these are the reason most competitors would fail a procurement review. The World Database on Protected Areas prohibits commercial use outright, and Earth Engine's free tier is noncommercial only. Both are extremely common in low-cost targeting workflows. We do not use either in the form that would breach them.
Attribution carried on all derived products: Contains data from DEMIRS / SLIP (Government of Western Australia), CC BY 4.0. Contains data from the South Australian Department for Energy and Mining, CC BY 4.0. Contains data from the NT Department of Mining and Energy (STRIKE), CC BY. Contains data from the Geological Survey of New South Wales, CC BY 4.0. © State of Queensland (Department of Resources), CC BY 4.0. Contains data from DEECA (State of Victoria), CC BY 4.0.
4. Conduct
Things we will not do.
We never hold tenure
Holding ground would make us a regulated mining entity with statutory expenditure, reporting and rehabilitation obligations — and a competitor to our own clients. We take royalties instead.
We never trade
We hold price-sensitive information about listed clients. We do not trade in any company we have worked for, or its neighbours, ever. It is in writing in every engagement.
We never promise a discovery
Prospectivity ranking changes the odds. It does not warrant the presence, quantity or quality of mineralisation, and anyone selling you certainty at this price is selling you something else.