EnviroMetal Technologies : Management Discussion and Analysis for the 3 and 9 month periods ended September 30, 2021

Management Discussion and Analysis

For the three and nine-month periods ended September 30, 2021 and 2020

EnviroMetal Technologies Inc.

Management Discussion and Analysis

For the three and nine-month periods ended September 30, 2021 and 2020

Introduction

This Management Discussion and Analysis (MDA) has been prepared to provide material updates and analysis of the business operations, financial condition, financial performance, cash flows, liquidity, and capital resources of EnviroMetal Technologies Inc. (EnviroMetal or the Company) (formerly EnviroLeach Technologies Inc.).

The information provided herein should be read in conjunction with the Company's unaudited condensed consolidated interim financial statements (Interim Financial Statements) and the notes thereto for the nine-month period ended September 30, 2021 and the audited consolidated financial statements for the year ended December 31, 2020.

The Financial Statements have been prepared in accordance with International Financial Reporting Standards (IFRS).

EnviroMetal Technologies Inc. is listed on the Canadian Securities Exchange (the CSE) under the symbol ETI and began trading on March 30, 2017. In addition to the listing on the CSE, the Company also trades on the OTCQX and Frankfurt Stock Exchange under the symbols EVLL and 7N2, respectively.

The Company has developed a unique, cost-effective, cyanide free, and more environmentally friendly alternative to current broadly used methods for the hydrometallurgical extraction of precious metals from ores, concentrates and other host material for use in the primary and secondary metals sectors.

Except as otherwise disclosed, all dollar figures in this report are stated in Canadian dollars. The effective date of this report is November 24, 2021.

Statements in this report that are not historical facts are forward-looking statements involving known and unknown risks and uncertainties, which could cause actual results to vary considerably from these statements. Readers are cautioned not to put undue reliance on forward-looking statements. See Forward-Looking Information and Statements herein.

Information related to the Company is available for view on SEDAR at www.sedar.comand additional information is also available on the Company's website at www.EnviroMetal.com.

Corporate Overview

EnviroMetal develops and markets technologies for the extraction of precious and other valuable metals from printed circuit board assemblies (PCBAs) and mineral concentrates in a safe, environmentally friendly, and sustainable manner. The Company's technology is used in the electronic waste (E-waste) processing industry to recover of gold and other valuable metals from printed circuit board assemblies; and the mining industry for the recovery of gold from of ores and concentrates. The Company operates a large pilot scale E-waste processing facility (EnviroCircuit) located in Surrey, British Columbia and is seeking opportunities to license its technology to companies in the mining and E-waste processing industries.

The EnviroMetal leach process is similar to conventional methods for the recovery of gold, but the Company's proprietary lixiviant formula and unique process eliminates the use of toxic leaching agents such as sodium cyanide or acid-based solutions. EnviroMetal's metal recovery technology targets industry participants seeking an on site or domestic processing solution with low logistics and third- party costs and a reduced environmental impact.

The EnviroMetal technology creates very strong differentiation in the marketplace and provides unique positioning. The pending and awarded patents combined with the process knowledge required for site optimization create significant barriers for competitors to overcome. The EnviroMetal process is cost competitive, safe, sustainable, and holds potential for multiple revenue streams.

Page | 2

EnviroMetal Technologies Inc.

Management Discussion and Analysis

For the three and nine-month periods ended September 30, 2021 and 2020

Overall Performance and Operations

During the period, the Company continued to pursue and develop commercial relationships in the primary and secondary metals industries for its patented metal recovery technology. In the primary metals industry, the Company is focussed on opportunities for the recovery of gold from concentrates and ores including In-Situ Recovery. In the secondary metals industry, the focus is the recovery of gold and other metals from electronic waste.

During the three and nine-month periods ended September 30, 2021, EnviroMetal continued to build and expand its E-waste supply network to feed the EnviroCircuit facility. The Company's supply network consists of small-scale recyclers and larger, integrated companies operating multiple facilities within the North American market. In addition, the Company continued to pursue international suppliers with encouraging results. Over 151 tonnes of E-waste were processed at EnviroCircuit during the nine-month period ended September 30, 2021. An additional 100+ tonnes of feedstock are currently in inventory at EnviroCircuit, and additional feedstock has been secured for processing during the fourth quarter of 2021.

EnviroMetal has and will continue to focus on the following operational and corporate objectives:

• Identify and secure feedstock to ensure the EnviroCircuit facility can operate continuously and efficiently;
• Enter partnerships and commercial agreements with integrated recycling companies;
• Advance existing letters of intent toward definitive agreements for technology licenses; and
• Pursue opportunities with mining partners that offer near term revenue potential.

Following the re-start of processing at EnviroCircuit in February 2021, the Company continued to identify and make improvements in process technologies to increase production, improve metal recoveries, and lower costs. In early July processing at EnviroCircuit was suspended in order to implement processing improvements which include upgraded grinding equipment, augmented non-ferrous recovery equipment, and enhanced mechanical separation. Despite delays in receiving some of the new equipment, the planned improvements and upgrades were substantially completed by the end of October. The Company anticipates the improvements will result in higher metal recoveries, reduced operating costs, and increased process throughput and efficiency.

The Company's laboratory and research facility continues research to expand the effectiveness of the EnviroMetal process to allow for the recovery of additional metals, including tin and copper, from PCBAs. The copper and tin recovery process targets copper/tin rich concentrates such as those produced at EnviroCircuit. The concentrates are treated with a hydrometallurgical process to dissolve copper and tin into solution under ambient temperature and pressure conditions. Following dissolution, the copper is recovered using conventional electrowinning technology as almost pure copper metal, and the tin is then removed from solution using proven physical separation methods to produce a marketable tin oxide product.

In June 2021, the Company entered into an agreement with Ocean Partners USA Inc., an affiliate of Ocean Partners Holdings Limited. Pursuant to the agreement EnviroMetal will use its patented and eco friendly metal extraction process to recover gold from gold mine materials. The Company also entered into a license agreement and a technology support and service agreement with HeliosX Corp. Pursuant to the license agreement, HeliosX Corp. may use the Company's technology to extract gold from concentrates and ores.

COVID-19 Pandemic Impacts

The COVID-19 pandemic has directly and dramatically impacted EnviroMetal's business. Due to isolation and quarantine requirements for businesses and limits on travel and commercial shipments, the E-waste supply chain and resulting supply of the Company's target

Page | 3

EnviroMetal Technologies Inc.

Management Discussion and Analysis

For the three and nine-month periods ended September 30, 2021 and 2020

feedstock of PCBAs was severely curtailed. Shortly after the EnviroCircuit pilot plant received R2/RIOS certification, which positioned the Company for commercial operations and revenue, almost all E-waste supply within the Company's supply network was disrupted.

While available supply was limited during the majority of 2020 and remains constrained, the Company has maintained consistent communication with electronics recyclers and other potential suppliers to continue to build business partnerships and identify supply opportunities. Market intelligence indicates the conditions limiting supply are slowly improving and the Company is pursuing commercial arrangements with multiple partners as recycling volumes increase.

The COVID-19 pandemic has not only affected the supply of available E-waste it has also affected international shipping. Shipping costs, container availability and port access have been impacted negatively. Higher shipping and port costs, and border, customs and port delays have resulted in delays in receiving feedstock, increased downtime, higher operating costs and delays in shipping finished materials to downstream processors.

Selected Annual Information

The Company had working capital of $2.5M as at September 30, 2021, an decrease of $40K over September 30, 2020. The change in working capital is the net result of $7.4M in net proceeds raised in the March and December 2020 private placements of units, offset by operating and corporate expenditures incurred in 2020 and during the first 3 quarters of 2021.

	Three months ended September 30	Nine months ended September 30,
		2021		2020		2021		2020
Revenues	$	19,540	$	573,572	$	624,708	$	830,749
Loss and comprehensive loss attributable to:
Shareholders		(2,268,709)		(1,019,693)		(4,644,839)		(4,165,999)
Non-controlling interest		-		(212,160)		(108,907)		(679,806)
	$	(2,268,709)	$	(1,231,853)	$	(4,753,746)	$	(4,845,805)
Loss per share - basic and diluted		(0.024)		(0.017)	$	(0.051)	$	(0.066)
				September 30,		December 31,		September 30,
				2021		2020		2020
Total assets			$	15,377,138	$	16,566,928	$	13,485,957
Total liabilities				5,357,455		2,132,625		1,752,773
Working capital				2,499,530		5,579,043		2,518,725

Page | 4

EnviroMetal Technologies Inc.

Management Discussion and Analysis

For the three and nine-month periods ended September 30, 2021 and 2020

Operational Financial results - For the three and nine-month periods ended September 30, 2021 and 2020

	Three months ended September 30,	Nine months ended September 30,
		2021		2020		2021		2020
Revenues	$	19,540	$	573,572	$	624,708	$	830,749
Expenses
Operating costs		(289,697)		(866,487)		(868,051)		(1,192,987)
Management and Employee costs		(393,338)		(347,417)		(1,096,411)		(1,152,726)
General and administration (Note 13)		(493,645)		(128,250)		(1,335,302)		(902,222)
Share-based payments (Note 11)		(30,213)		-		(30,213)		(985,890)
		(1,206,893)		(1,342,154)		(3,329,977)		(4,233,825)
Loss before other items		(1,187,353)		(768,582)		(2,705,269)		(3,403,076)

Revenues- The Company recognized revenue of $19,540 and $624,708 during the three and nine-month periods ended September 30, 2021 from the sale of recovered metals as compared to $573,572 and $830,749 during the 2020 comparative periods. The re-start of the E-waste processing plant following the COVID shutdown resulted in a 64% increase in revenues during the first six months of 2021 as compared to 2020, after allocation of an adjustment to the revenues recorded during the third quarter of 2021. The temporary suspension of operations in Q3 for plant upgrades, combined with an adjustment of $182,500 to revenues recorded in Q1 and 2 of 2121, have negatively affected the revenues during the three-month period ended September 30, 2021.

Operating Expenses- The operating expenses to sales ratio during the nine-month period ended September 30, 2021 was 1.39 as compared to 1.80 for the nine-month period ended September 30, 2020. The improvement of the ratio is primarily due to changes to the plant process flow and reduction of expenses related to the commissioning of the EnviroCircuit plant, offset by increased freight costs linked to current port congestion. The Company also benefited from government rent subsidies, amounting to $37,570 and $123,477 for the three and nine-month periods ended September 30, 2021, respectively (2020 - $nil). Included in operating expenses are laboratory costs which were reduced by 11% and 48% during the three and nine-month periods ended September 30, 2021, respectively, as compared to the same periods in 2020 following efficiency gains in testing and reduced development costs, with expenses totalling $15,621 and $43,853 for the three and nine-month periods ended September 30, 2021.

Management and Employee costs- Management and employee compensation costs during the three and nine-month periods ended September 30, 2021 were partially offset by Canada Emergency Wage Subsidies of $105,327 and $318,967, respectively (2020 - $219,466 and $396,713, respectively). The Company also benefited from wage subsidies of $37,706 and $90,723, respectively (2020

• $33,943 and $365,503, respectively) from IRAP associated with its research on copper and tin recoveries and participation in youth programs. The wage subsidies have partially offset the increase in compensation related to new hires, resulting in a year-to-year decrease of 5% in management and employee costs.

Page | 5