Hudbay Minerals (NYSE: HBM) files 2024 ESTMA resource payment report

Rhea-AI Filing Summary

Hudbay Minerals Inc. filed a Specialized Disclosure Report under Rule 13q-1 for the fiscal year ended December 31, 2024. The company states that conflict minerals disclosure requirements are not applicable for this period.

Hudbay explains that it is subject to Canada's Extractive Sector Transparency Measures Act (ESTMA) and has filed an annual ESTMA report with the Government of Canada. The SEC has deemed ESTMA an alternative reporting regime for Rule 13q-1, so Hudbay is using its consolidated Annual ESTMA Report for 2024, filed as Exhibit 2.01, to satisfy the U.S. resource extraction payment disclosure requirements.

  UNITED STATES

SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

FORM SD

SPECIALIZED DISCLOSURE REPORT

HUDBAY MINERALS INC.

Canada	001-34244	98-0485558
(State or other jurisdiction of incorporation or organization)	(Commission File Number)	(I.R.S. Employer Identification No.)

25 York Street, Suite 800 Toronto, Ontario Canada	M5J 2V5
(Address of Principal Executive Offices)	(Zip Code)

Patrick Donnelly

Hudbay Minerals Inc.

(416) 362-8181

(Name and telephone number, including area code, of the person to contact in connection with this report.)

Check the appropriate box to indicate the rule pursuant to which this form is being filed:

o	Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2024.
√	Rule 13q-1 under the Securities Exchange Act (17 CFR 240.13q-1) for the fiscal year ended December 31, 2024.

Section 1 - Conflict Minerals Disclosure

Item 1.01 Conflict Minerals Disclosure and Report

Not applicable.

Item 1.02 Exhibit

Not applicable.

Section 2 - Resource Extraction Issuer Disclosure

Item 2.01 Resource Extraction Issuer Disclosure and Report

Hudbay Minerals Inc. (the "Company") is subject to the reporting obligations under Canada's Extractive Sector Transparency Measures Act ("ESTMA"). In accordance with the reporting obligations under ESTMA, the Company has filed an annual report with the Government of Canada, which, in aggregate, discloses the resource extraction payments made by the Company and its subsidiaries during the prior fiscal year, on a consolidated basis (the "Annual ESTMA Report").

The United States Securities and Exchange Commission has deemed ESTMA to be an "alternative reporting regime" for the purposes of satisfying the disclosure requirements of Rule 13q-1 of the Securities Exchange Act of 1934, as amended. Accordingly, the Company is relying on the alternative reporting provision of Item 2.01 and is providing the Annual ESTMA Report for the year ended December 31, 2024 to satisfy the requirements of Item 2.01.

Section 3 - Exhibits

Item 3.01 Exhibits

The following exhibit is being filed as part of this Report.

Exhibit No.	Description
2.01	ESTMA Report for the Year Ended December 31, 2024 for Hudbay Minerals Inc.

SIGNATURES

Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.

HUDBAY MINERALS INC.
By:	/s/ Patrick Donnelly		Date:	August 28, 2025
Name: Patrick Donnelly
Title: Senior Vice President, Legal and Organizational Effectiveness

FAQ

What does Hudbay Minerals (HBM) report in its 2024 Form SD?

Hudbay Minerals Inc. filed a Form SD under Rule 13q-1 for the year ended December 31, 2024, relying on its Canadian ESTMA annual report to disclose resource extraction payments.

Does Hudbay Minerals (HBM) provide conflict minerals disclosure in this filing?

No. The company states that conflict minerals disclosure is not applicable for the reporting period, and therefore Items 1.01 and 1.02 are marked not applicable.

How does Hudbay Minerals satisfy U.S. resource extraction disclosure rules?

Hudbay relies on Canada's Extractive Sector Transparency Measures Act (ESTMA), which the SEC has deemed an alternative reporting regime for Rule 13q-1, and provides its Annual ESTMA Report.

What period does Hudbay Minerals' 2024 resource extraction disclosure cover?

The disclosure covers the fiscal year ended December 31, 2024, consistent with the period of the company’s Annual ESTMA Report filed as Exhibit 2.01.

What exhibit is included with Hudbay Minerals' 2024 Form SD?

The filing includes Exhibit 2.01, titled "ESTMA Report for the Year Ended December 31, 2024 for Hudbay Minerals Inc.", which contains the detailed payment information.

Why can Hudbay use ESTMA reporting to comply with SEC Rule 13q-1?

The SEC has deemed ESTMA to be an alternative reporting regime that satisfies Rule 13q-1, allowing Hudbay to use its Annual ESTMA Report instead of a separate U.S.-specific payment report.