As filed with the Securities and Exchange Commission on January 26, 2022
 
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
 
FORM N-CSR
 
CERTIFIED SHAREHOLDER REPORT OF REGISTERED MANAGEMENT

INVESTMENT COMPANIES

 
Investment Company Act file number 811-21650
 
ASA GOLD AND PRECIOUS METALS LIMITED
Three Canal Plaza, Suite 600
Portland, ME  04101
 
Karen Shaw, Principal Financial Officer
Three Canal Plaza, Suite 600
Portland, Maine 04101
207-347-2000
 
 
Date of fiscal year end: November 30
 
Date of reporting period: December 1 – November 30
 
 

ITEM 1. REPORT TO STOCKHOLDERS.
 
Annual
Report
and
Financial
Statements
November
30,
2021
A
Closed-End
Fund
Specializing
in
Gold
and
Other
Precious
Metals
Investments
1
ASA
Gold
and
Precious
Metals
Limited
Table
of
Contents
Annual
Report
and
Financial
Statements
November
30,
2021
Letter
to
Shareholders
(Unaudited)
2
Forward-looking
statements
4
10-Year
performance
returns
(Unaudited)
5
Certain
investment
policies
and
restrictions
(Unaudited)
7
Report
of
Independent
Registered
Public
Accounting
Firm
8
Schedule
of
investments
9
Portfolio
statistics
(Unaudited)
12
Statement
of
assets
and
liabilities
13
Statement
of
operations
14
Statements
of
changes
in
net
assets
15
Notes
to
financial
statements
16
Financial
highlights
21
Certain
tax
information
for
U.S.
shareholders
(Unaudited)
22
Dividend
reinvestment
and
stock
purchase
plan
(Unaudited)
22
Privacy
notice
(Unaudited)
23
Form
N-PX/proxy
voting
(Unaudited)
23
Form
N-PORT/portfolio
holdings
(Unaudited)
23
Share
repurchase
(Unaudited)
23
Company
investment
objective,
investment
strategy
and
risks
(Unaudited)
23
Board
of
directors
and
officers
(Unaudited)
26
2
Dear
Shareholder,
Fiscal
2021
was
a
volatile
period
for
gold.
In
the
last
twelve
months,
there
were
nine
price
moves
greater
than
$100/oz,
yet
the
price
of
gold
was
essentially
flat.
The
gold
price
ranged
from
a
high
of
$1,959
to
a
low
of
$1,677,
ending
the
fiscal
year
at
$1,775.
Price
fluctuations
were
attributed
to
concerns
and
optimism
surrounding
Covid-19,
conflicting
economic
data,
the
Federal
Reserve’s
(the
“Fed”)
tapering,
and
questions
around
when
the
Fed
will
begin
to
increase
interest
rates.
Gold
decreased
0.1%
during
the
fiscal
year
ended
November
30,
2021,
while
ASA
Gold
and
Precious
Metals
Limited
(“ASA”,
the
“Fund”
or
the
“Company”)
reported
a
total
return
of
4.0%
based
on
its
net
asset
value
(“NAV”),
compared
to
a
total
return
decrease
of
7.3%
for
the
NYSE
Arca
Gold
Miners
Index
(the
“Index”).
Total
return
of
ASA’s
share
price
for
the
fiscal
year
was
4.1%.
At
fiscal
year-end,
total
net
assets
of
ASA
were
$481
million,
an
increase
of
$17
million
as
compared
to
fiscal
year-end
2020.
The
Company’s
average
expense
ratio
dropped
to
0.91%
during
the
2021
fiscal
year
from
1.02%
during
fiscal
year
2020
due
to
investment
performance
and
the
corresponding
increase
in
assets.
For
the
fiscal
year
ended
November
30,
2021,
Merk
Investments
(“Merk”),
the
Fund’s
investment
adviser,
proactively
agreed
to
a
scaled
decrease
in
investment
adviser
fees
on
an
asset
level
basis
above
$300
million
in
net
assets,
which
also
benefited
the
expense
ratio.
Separately,
investment
income
increased
to
$2.7
million
during
fiscal
year
2021
from
$1.3
million
during
2020,
which
was
primarily
due
to
some
of
the
producing
companies
in
the
portfolio
increasing
dividend
payouts.
The
discount
at
which
ASA’s
shares
traded
in
the
market
fluctuated
during
the
year
from
a
high
of
18.1%
to
a
low
of
10.1%
and
ended
the
fiscal
year
at
17.1%.
The
Board
of
Directors
of
ASA
and
Merk
monitor
the
Company’s
share
price
and
discount
to
NAV
on
an
ongoing
basis.
Annual
portfolio
turnover
has
somewhat
stabilized
since
Merk
took
over
the
management
of
the
portfolio
in
2019.
We
are
pleased
with
the
current
construction
of
the
portfolio
and
now
are
at
a
point
where
we
constantly
manage
risk
versus
reward
when
adding
or
subtracting
names.
Although
the
Company
does
not
maintain
a
formal
distribution
policy,
the
Company
has
paid
uninterrupted
distributions
since
1959,
and
expects
to
make
distributions
on
a
semi-annual
basis
(in
May
and
November)
to
shareholders.
The
Company’s
distributions
have
been
the
same
amount
per
share
since
November
2018,
including
the
most
recent
distribution,
paid
on
November
24,
2021.
In
general,
these
distributions
do
not
affect
the
Company’s
investment
strategy
and
may
reduce
the
Fund’s
NAV.
 For
the
12-month
period
ended
November
30,
2021,
none
of
the
Company’s
distributions
will
be
treated
as
a
return
of
capital
for
tax
purposes.  
You
should
not
draw
any
conclusions
about
the
Company’s
investment
performance
from
the
source
or
amount
of
the
distributions.
We
continue
to
believe
that
the
U.S.
dollar
is
in
a
long-term
bear
market.
Also,
we
think
the
price
of
gold
should
be
supported
by
ongoing
negative
real
interest
rates
(i.e.,
nominal
interest
rates
below
inflation
rates).
If
the
Fed
hikes
interest
rates
faster
than
currently
anticipated
by
the
market,
it
may
hasten
an
economic
downturn
that
leads
to
rates
going
back
down
to
near-zero.
Overall,
we
expect
volatility
in
the
gold
price
to
continue
and
believe
that
company
specific
catalysts
will
provide
outperformance.
As
we
have
stated
in
previous
letters
and
shown
over
the
last
twelve
months,
the
Fund
has
moved
into
a
position
where
we
believe
there
is
better
leverage
to
the
gold
price.
Stock
selection
on
the
smaller
capitalization
companies
has
shown
to
be
the
right
decision.
The
following
table
shows
the
breakdown
by
stage
of
company
and
the
performance
attribution
for
each
over
the
last
fiscal
year:
3
Large:
annual
production
>
1,000,000
ounces
Medium:
annual
production
500,000
1,000,000
ounces
Small:
annual
production
<
500,000
ounces
Attribution:
a
measure
of
the
relative
contribution
to
the
performance
Our
thesis
is
that
larger
capitalization
companies
are
more
inclined
to
perform
in
line
with
the
gold
price,
whereas
the
exploration,
development
and
smaller
producers
have
catalysts
that
will
drive
outperformance.
The
attribution
table
above
shows
the
effect
on
our
portfolio.
A
number
of
our
exploration
holdings
have
had
success
with
the
drill
bit
and
driven
the
majority
of
our
annual
performance.
The
development
companies
are
in
the
build
out
stage
and
we
believe
they
should
start
to
see
improved
performance
as
the
ramp
up
to
production
is
closer.
Additionally,
a
timely
move
into
silver
and
copper/gold
projects
has
been
encouraging
for
the
Fund.
Operationally,
we
believe
most
of
the
producing
companies
have
been
performing
well
and
generating
free
cash
flow
with
nice
dividends.
Unfortunately,
their
performance
has
been
driven
mostly
by
the
commodity.
We
continue
to
believe
that
these
companies
need
to
find
new
projects
to
improve
their
growth
pipeline.
In
that
vein,
mergers
and
acquisition
(M&A)
activity
has
been
increasing
throughout
the
year,
with
a
number
of
deals
in
the
smaller
capitalization
part
of
the
sector.
The
Agnico
Eagle/Kirkland
Lake
transaction
in
the
fourth
quarter,
though,
was
primarily
done
to
appease
the
generalist
investor
and
create
a
new
alternative
to
the
largest
companies
Newmont
Mining
and
Barrick
Gold.
It
does
not
solve
what
we
see
as
the
increasing
irrelevance
of
the
mid-capitalization
companies.
In
that
environment,
we
believe
our
portfolio
is
positioned
to
benefit
with
projects
that
could
be
a
source
of
growth
to
companies
that
are
showing
little
future
growth
in
their
production
pipelines.
We
continue
to
wish
everyone
health
and
safety
during
this
period
of
global
uncertainty.
As
always,
please
reach
out
to
us
if
you
have
any
questions.
Peter
Maletis,
Portfolio
Manager
Axel
Merk,
Chief
Investment
Officer
Merk
Investments
LLC
Merk
Investments
LLC
4
Forward-Looking
Statements
Forward-looking
statements
This
shareholder
letter
includes
forward-looking
statements,
which
involve
known
and
unknown
risks,
uncertainties
and
other
factors
that
may
cause
the
actual
results,
levels
of
activity,
performance
or
achievements
of
the
Company,
or
industry
results,
to
be
materially
different
from
any
future
results,
levels
of
activity,
performance
or
achievements
expressed
or
implied
by
such
forward-looking
statements.
The
Company’s
actual
performance
or
results
may
differ
from
its
beliefs,
expectations,
estimates,
goals
and
projections,
and
consequently,
investors
should
not
rely
on
these
forward-
looking
statements
as
predictions
of
future
events.
Forward-looking
statements
are
not
historical
in
nature
and
generally
can
be
identified
by
words
such
as
“believe,”
“anticipate,”
“estimate,”
“expect,”
“intend,”
“should,”
“may,”
“will,”
“seek,”
or
similar
expressions
or
their
negative
forms,
or
by
references
to
strategy,
plans,
goals
or
intentions.
The
absence
of
these
words
or
references
does
not
mean
that
the
statements
are
not
forward-looking.
The
Company’s
performance
or
results
can
fluctuate
from
month
to
month
depending
on
a
variety
of
factors,
a
number
of
which
are
beyond
the
Company’s
control
and/or
are
difficult
to
predict,
including
without
limitation:
the
Company’s
investment
decisions,
the
performance
of
the
securities
in
its
investment
portfolio,
economic,
political,
market
and
financial
factors,
and
the
prices
of
gold,
platinum
and
other
precious
minerals
that
may
fluctuate
substantially
over
short
periods
of
time.
The
Company
may
or
may
not
revise,
correct
or
update
the
forward-looking
statements
as
a
result
of
new
information,
future
events
or
otherwise.
The
Company
concentrates
its
investments
in
the
gold
and
precious
minerals
sector.
This
sector
may
be
more
volatile
than
other
industries
and
may
be
affected
by
movements
in
commodity
prices
triggered
by
international
monetary
and
political
developments.
The
Company
is
a
non-diversified
fund
and,
as
such,
may
invest
in
fewer
investments
than
that
of
a
diversified
portfolio.
The
Company
may
invest
in
smaller-sized
companies
that
may
be
more
volatile
and
less
liquid
than
larger
more
established
companies.
Investments
in
foreign
securities,
especially
those
in
the
emerging
markets,
may
involve
increased
risk
as
well
as
exposure
to
currency
fluctuations.
Shares
of
closed-end
funds
frequently
trade
at
a
discount
to
net
asset
value.
All
performance
information
reflects
past
performance
and
is
presented
on
a
total
return
basis.
Past
performance
is
no
guarantee
of
future
results.
Current
performance
may
differ
from
the
performance
shown.
This
shareholder
letter
does
not
constitute
an
offer
to
sell
or
solicitation
of
an
offer
to
buy
any
securities.
5
10-Year
Performance
Returns
Comparison
of
Change
in
Value
of
a
$10,000
Investment
ASA
Gold
and
Precious
Metals
Share
Price
and
NYSE
ARCA
Gold
Miners
Index(1)
The
following
chart
reflects
the
change
in
the
value
of
a
hypothetical
$10,000
investment,
including
reinvested
dividends
and
distributions,
in
ASA
Gold
and
Precious
Metals,
Ltd.
(the
“Company”)
compared
with
the
performance
of
the
benchmark,
NYSE
ARCA
Gold
Miners
Index,
over
the
past
ten
fiscal
years.
The
total
return
of
the
index
includes
the
reinvestment
of
dividends
and
income.
The
total
return
of
the
Company
includes
operating
expenses
that
reduce
returns,
while
the
total
return
of
the
indices
do
not
include
expenses.
The
Company
is
professionally
managed,
while
the
index
is
unmanaged
and
is
not
available
for
investment.
Fiscal
Year
Total
Returns
Best
Quarter
(NAV):
Q2
2020
80.11%
Worst
Quarter
(NAV):
Q2
2013
-34.36%
6
The
performance
data
quoted
represent
past
performance
and
do
not
indicate
future
results.
Current
performance
may
be
lower
or
higher
than
the
performance
data
quoted.
For
more
current
performance
data,
please
visit
http://www.asaltd.com/investor-information/factsheets.
The
results
shown
in
the
table
reflect
the
reinvestment
of
income
dividends
and
other
distributions,
if
any.
The
results
do
not
reflect
the
effect
of
taxes
a
shareholder
would
pay
on
Company
distributions
or
on
the
sale
of
the
Company’s
common
shares.
The
investment
return
and
market
price
will
fluctuate
and
the
Company’s
common
shares
may
trade
at
prices
above
or
below
NAV.
The
Company’s
common
shares,
when
sold,
may
be
worth
more
or
less
than
their
original
cost
.
For
more
complete
information
about
the
Company,
please
call
us
directly
at
1-800-432-3378,
or
visit
the
Company’s
website
at
www.asaltd.com
.
Average
Annual
Total
Returns
For
the
years
ended
November
30,
2021
1
Year
3
Year
5
Year
10
Year
ASA
Gold
and
Precious
Metals
-
NAV
3.96%
35.41%
14.89%
-2.07%
ASA
Gold
and
Precious
Metals
-
Share
Price
4.06%
33.88%
14.11%
-2.75%
FTSE
Gold
Mines
Index(1)
-9.92%
19.26%
9.54%
-5.17%
NYSE
ARCA
Gold
Miners
Index
(NTR)(1)
-7.25%
19.50%
9.84%
3.97%
(1)
The
FTSE
Gold
Mines
Total
Return
Index
(“FTSE
Gold
Index”)
encompasses
gold
mining
companies
that
have
a
sustainable,
attributable
gold
production
of
at
least
300,000
ounces
a
year
and
that
derive
51%
or
more
of
their
revenue
from
mined
gold.
Please
note
that
the
Index
is
unmanaged,
and
does
not
take
into
account
any
fees
and
expenses
or
any
tax
consequences
of
investing
in
the
individual
securities
that
it
tracks
and
one
cannot
invest
directly
in
the
Index.
The
NYSE
Arca
Gold
Miners
Index
(the
“Index”)
is
a
net
total
return
modified
capitalization
weighted
index
comprised
of
publicly
traded
companies
primarily
involved
in
the
mining
of
gold
and
silver
in
locations
around
the
world.
The
Company
does
not
attempt
to
replicate
the
FTSE
Gold
Index
or
the
Index.
The
FTSE
Gold
Index
and
Index
do
not
necessarily
reflect
investments
in
other
precious
metals
companies
(e.g.,
silver,
platinum,
and
diamonds)
in
which
the
Company
may
invest.
Data
about
the
performance
of
the
FTSE
Gold
Index
and
Index
are
prepared
or
obtained
by
Management
and
include
reinvestment
of
all
income
dividends
and
other
distributions,
if
any.
The
Fund
may
invest
in
securities
not
included
in
the
FTSE
Gold
Index
or
Index
and
does
not
invest
in
all
securities
included
in
the
FTSE
Gold
Index
or
Index.
7
Certain
Investment
Policies
and
Restrictions
The
following
is
a
summary
of
certain
of
the
Company’s
investment
policies
and
restrictions
and
is
subject
to
the
more
complete
statements
contained
in
documents
filed
with
the
Securities
and
Exchange
Commission.
The
concentration
of
investments
in
a
particular
industry
or
group
of
industries.
It
is
a
fundamental
policy
(i.e.,
a
policy
that
may
be
changed
only
by
shareholder
vote)
of
the
Company
that
at
least
80%
of
its
total
assets
be
(i)
invested
in
common
shares
or
securities
convertible
into
common
shares
of
companies
engaged,
directly
or
indirectly,
in
the
exploration,
mining
or
processing
of
gold,
silver,
platinum,
diamonds
or
other
precious
minerals,
(ii)
held
as
bullion
or
other
direct
forms
of
gold,
silver,
platinum
or
other
precious
minerals,
(iii)
invested
in
instruments
representing
interests
in
gold,
silver,
platinum
or
other
precious
minerals
such
as
certificates
of
deposit
therefor,
and/or
(iv)
invested
in
securities
of
investment
companies,
including
exchange
traded
funds,
or
other
securities
that
seek
to
replicate
the
price
movement
of
gold,
silver
or
platinum
bullion.
Compliance
with
the
percentage
limitation
relating
to
the
concentration
of
the
Company’s
investments
will
be
measured
at
the
time
of
investment.
If
investment
opportunities
deemed
by
the
Company
to
be
attractive
are
not
available
in
the
types
of
securities
referred
to
above,
the
Company
may
deviate
from
the
investment
policy
outlined
in
that
paragraph
and
make
temporary
investments
of
unlimited
amounts
in
securities
issued
by
the
U.S.
Government,
its
agencies
or
instrumentalities
or
other
high
quality
money
market
instruments.
The
percentage
of
voting
securities
of
any
one
issuer
that
the
company
may
acquire.
It
is
a
non-fundamental
policy
(i.e.,
a
policy
that
may
be
changed
by
the
Board
of
Directors)
of
the
Company
that
the
Company
shall
not
purchase
a
security
if,
at
the
time
of
purchase,
more
than
20%
of
the
value
of
its
total
assets
would
be
invested
in
securities
of
the
issuer
of
such
security.
8
Report
of
Independent
Registered
Public
Accounting
Firm
Report
of
Independent
Registered
Public
Accounting
Firm
To
the
Board
of
Directors
and
Shareholders
of
ASA
Gold
and
Precious
Metals
Limited
Opinion
on
the
Financial
Statements
We
have
audited
the
accompanying
statement
of
assets
and
liabilities
of
ASA
Gold
and
Precious
Metals
Limited
(the
“Company”),
including
the
schedule
of
investments,
as
of
November
30,
2021,
the
related
statement
of
operations
for
the
year
then
ended,
statements
of
changes
in
net
assets
for
each
of
the
two
years
in
the
period
then
ended,
and
financial
highlights
for
each
of
the
five
years
in
the
period
then
ended,
and
the
related
notes
(collectively
referred
to
as
the
“financial
statements”).
In
our
opinion,
the
financial
statements
present
fairly,
in
all
material
respects,
the
financial
position
of
the
Company
as
of
November
30,
2021,
the
results
of
its
operations
for
the
year
then
ended,
the
changes
in
its
net
assets
for
each
of
the
two
years
in
the
period
then
ended,
and
the
financial
highlights
for
each
of
the
five
years
in
the
period
then
ended,
in
conformity
with
accounting
principles
generally
accepted
in
the
United
States
of
America.
Basis
for
Opinion
These
financial
statements
are
the
responsibility
of
the
Company’s
management.
Our
responsibility
is
to
express
an
opinion
on
the
Company’s
financial
statements
based
on
our
audits.
We
are
a
public
accounting
firm
registered
with
the
Public
Company
Accounting
Oversight
Board
(United
States)
(“PCAOB”)
and
are
required
to
be
independent
with
respect
to
the
Fund
in
accordance
with
the
U.S.
federal
securities
laws
and
the
applicable
rules
and
regulations
of
the
Securities
and
Exchange
Commission
and
the
PCAOB.
We
have
served
as
the
Company’s
auditor
since
2012.
We
conducted
our
audits
in
accordance
with
the
standards
of
the
PCAOB.
Those
standards
require
that
we
plan
and
perform
the
audits
to
obtain
reasonable
assurance
about
whether
the
financial
statements
are
free
of
material
misstatement,
whether
due
to
error
or
fraud.
The
Company
is
not
required
to
have,
nor
were
we
engaged
to
perform,
an
audit
of
its
internal
control
over
financial
reporting.
As
part
of
our
audits
we
are
required
to
obtain
an
understanding
of
internal
control
over
financial
reporting,
but
not
for
the
purpose
of
expressing
an
opinion
on
the
effectiveness
of
the
Company’s
internal
control
over
financial
reporting.
Accordingly,
we
express
no
such
opinion.
Our
audits
included
performing
procedures
to
assess
the
risks
of
material
misstatement
of
the
financial
statements,
whether
due
to
error
or
fraud,
and
performing
procedures
that
respond
to
those
risks.
Such
procedures
included
examining,
on
a
test
basis,
evidence
regarding
the
amounts
and
disclosures
in
the
financial
statements.
Our
audits
also
included
evaluating
the
accounting
principles
used
and
significant
estimates
made
by
management,
as
well
as
evaluating
the
overall
presentation
of
the
financial
statements.
Our
procedures
included
confirmation
of
securities
owned
as
of
November
30,
2021
by
correspondence
with
the
custodians.
We
believe
that
our
audit
provide
a
reasonable
basis
for
our
opinion.
TAIT,
WELLER
&
BAKER
LLP
Philadelphia,
Pennsylvania
January
19,
2022
9
The
notes
to
financial
statements
form
an
integral
part
of
these
statements.
Schedule
of
Investments
Schedule
of
investments
November
30,
2021
Name
of
Company
Shares
Value
%
of
Net
Assets
Common
Shares
Gold
mining,
exploration,
development
and
royalty
companies
Australia
Alicanto
Minerals,
Ltd.
(1)
25,000,004
$
2,227,656‌
0.5‌
%
Barton
Gold
Holdings,
Ltd.
(1)
8,600,000
1,287,407‌
0.3‌
Bellevue
Gold,
Ltd.
(1)
7,666,667
4,344,820‌
0.9‌
Bellevue
Gold,
Ltd.
(1)
1,300,000
736,730‌
0.2‌
Cygnus
Gold,
Ltd.
(1)
7,500,000
1,015,811‌
0.2‌
Dacian
Gold,
Ltd.
(1)
13,842,639
2,022,883‌
0.4‌
Emerald
Resources
NL
(1)
17,125,000
13,001,044‌
2.7‌
Los
Cerros
,
Ltd.
(1)
28,437,500
2,635,317‌
0.5‌
Los
Cerros
,
Ltd.
(1)
2,187,500
202,717‌
0.0‌
Pantoro
,
Ltd.
(1)
16,000,000
3,763,847‌
0.8‌
Perseus
Mining,
Ltd.
11,000,000
12,859,811‌
2.7‌
Predictive
Discovery,
Ltd.
(1)
63,850,000
10,696,133‌
2.2‌
Predictive
Discovery,
Ltd.
(1)
4,000,000
670,079‌
0.1‌
Prodigy
Gold
NL
(1)
38,750,000
1,022,048‌
0.2‌
56
,
486
,
303‌
11
.
7‌
Canada
Agnico
Eagle
Mines,
Ltd.
200,000
9,960,000‌
2.1‌
Alamos
Gold,
Inc.
1,200,000
9,168,000‌
1.9‌
B2Gold
Corp.
2,000,000
7,880,000‌
1.6‌
Barrick
Gold
Corp.
700,000
13,293,000‌
2.8‌
Calibre
Mining
Corp.
(1)
11,083,000
11,712,435‌
2.4‌
Desert
Gold
Ventures,
Inc.
(1)
13,400,000
1,363,654‌
0.3‌
G
Mining
Ventures
Corp.
(1)
17,843,965
12,012,846‌
2.5‌
GoGold
Resources,
Inc.
(1)
2,857,140
7,291,304‌
1.5‌
HighGold
Mining,
Inc.
(1)
3,000,000
3,616,580‌
0.7‌
K92
Mining,
Inc.
(1)
1,725,000
9,992,563‌
2.1‌
Liberty
Gold
Corp.
(1)
11,082,000
9,369,103‌
1.9‌
Marathon
Gold
Corp.
(1)
5,039,200
11,873,648‌
2.5‌
Mawson
Gold,
Ltd.
(1)
8,600,000
1,077,146‌
0.2‌
Millennial
Precious
Metals
Corp.
(1)
12,333,333
5,116,965‌
1.1‌
Monarch
Mining
Corp.
(1)
5,600,000
3,156,288‌
0.6‌
Newcore
Gold,
Ltd.
(1)
5,750,000
2,385,612‌
0.5‌
Nighthawk
Gold
Corp.
(1)
4,348,000
2,927,144‌
0.6‌
O3
Mining,
Inc.
(1)
2,223,000
3,619,586‌
0.7‌
Orla
Mining,
Ltd.
(1)
8,200,000
35,112,137‌
7.3‌
Osino
Resources
Corp.
(1)
4,000,000
3,694,861‌
0.8‌
Prime
Mining
Corp.
(1)
6,450,000
23,680,379‌
4.9‌
Probe
Metals,
Inc.
(1)
4,725,000
6,731,770‌
1.4‌
Roscan
Gold
Corp.
(1)
10,886,900
2,982,829‌
0.6‌
Skeena
Resources,
Ltd.
(1)
700,000
6,678,000‌
1.4‌
SSR
Mining,
Inc.
1,050,000
19,067,692‌
4.0‌
Talisker
Resources,
Ltd.
(1)
6,500,000
1,602,802‌
0.3‌
TDG
Gold
Corp.
(1)
6,977,925
2,731,193‌
0.6‌
Thesis
Gold,
Inc.
(1)
4,400,000
4,408,783‌
0.9‌
Westhaven
Gold
Corp.
(1)
5,500,000
1,851,344‌
0.4‌
234,357,664‌
48.6‌
Cayman
Islands
Endeavour
Mining
PLC
860,000
20,176,289‌
4.2‌
10
The
notes
to
financial
statements
form
an
integral
part
of
these
statements.
Name
of
Company
Shares
Value
%
of
Net
Assets
Common
Shares
(continued)
Gold
mining,
exploration,
development
and
royalty
companies
(continued)
South
Africa
AngloGold
Ashanti,
Ltd.
ADR
800,000
$
16,752,000‌
3.5‌
%
Gold
Fields,
Ltd.
ADR
1,500,000
17,010,000‌
3.5‌
33,762,000‌
7.0‌
Total
gold
mining,
exploration,
development
and
royalty
companies
(Cost
$179,729,468)
3
44
,
782
,
256‌
7
1
.
5‌
Diversified
metals
mining,
exploration,
development
and
royalty
companies
Australia
Auteco
Minerals,
Ltd.
(1)
70,750,750
3,580,861‌
0.7‌
Castile
Resources,
Ltd.
(1)
12,500,000
1,782,125‌
0.4‌
Geopacific
Resources,
Ltd.
(1)
17,857,143
2,673,187‌
0.6‌
Red
Dirt
Metals,
Ltd.
(1)
11,338,600
5,900,385‌
1.2‌
13
,
936
,
558‌
2
.
9‌
Canada
Adventus
Mining
Corp.
(1)
5,310,000
3,782,614‌
0.8‌
Americas
Gold
&
Silver
Corp.
(1)
1,975,000
1,599,553‌
0.3‌
Americas
Gold
&
Silver
Corp.
(1)
1,555,000
1,278,132‌
0.3‌
Americas
Gold
&
Silver
Corp.
(1)(2)
1,071,400
867,727‌
0.2‌
Arizona
Metals
Corp.
(1)
2,400,000
9,788,250‌
2.0‌
Aya
Gold
&
Silver,
Inc.
(1)
2,400,000
18,261,380‌
3.8‌
Benchmark
Metals,
Inc.
(1)
7,384,615
6,301,014‌
1.3‌
Bunker
Hill
Mining
Corp.
(1)
14,214,957
2,893,177‌
0.6‌
Emerita
Resources
Corp.
(1)
2,750,000
6,888,724‌
1.4‌
Euro
Sun
Mining,
Inc.
(1)
11,000,000
2,454,108‌
0.5‌
Huntington
Exploration,
Inc.
(1)
7,900,000
1,236,839‌
0.3‌
Huntsman
Exploration,
Inc.
(1)
6,175,000
290,031‌
0.1‌
Integra
Resources
Corp.
(1)
2,679,999
5,874,200‌
1.2‌
Integra
Resources
Corp.
(1)
550,001
1,199,002‌
0.2‌
Pan
Global
Resources,
Inc.
(1)
6,667,000
3,548,914‌
0.7‌
Sable
Resources,
Ltd.
(1)
26,160,000
4,300,442‌
0.9‌
70
,
564
,
107‌
1
4
.
6‌
United
Kingdom
Adriatic
Metals
PLC
(1)
2,500,000
4,722,630‌
1.0‌
Total
diversified
metals
mining,
exploration,
development
and
royalty
companies
(Cost
$63,437,782)
8
9
,
223
,
295‌
1
8
.
5‌
Silver
mining,
exploration,
development
and
royalty
companies
Canada
Andean
Precious
Metals
Corp.
(1)
2,000,000
2,270,148‌
0.5‌
Discovery
Silver
Corp.
(1)
1,555,556
2,301,461‌
0.5‌
Discovery
Silver
Corp.
(1)
4,444,444
6,575,599‌
1.4‌ 
Silver
Tiger
Metals,
Inc.
(1)
10,595,333
4,893,535‌
1.0‌
1
6
,
040
,
743‌
3
.
4‌
South
Africa
Sibanye
Stillwater,
Ltd.
ADR
273,043
3,396,654‌
0.7‌
Total
silver
mining,
exploration,
development
and
royalty
companies
(Cost
$7,876,838)
19
,
437
,
397‌
4.
1‌
Total
common
shares
(Cost
$251,044,088
)
453,442,948‌
94.1‌
Rights
Silver
mining,
exploration,
development
and
royalty
companies
Canada
Pan
American
Silver
Corp.
(Expiration
Date
2/22/29)
(1)(3)
393,200
149,731‌
0.0‌
Total
rights
(Cost
$136,720)
149,731‌
0.0‌
Schedule
of
Investments
(continued)
November
30,
2021
11
The
notes
to
financial
statements
form
an
integral
part
of
these
statements.
Name
of
Company
Shares
Value
%
of
Net
Assets
Warrants
Diversified
metals
mining,
exploration,
development
and
royalty
companies
Australia
Red
Dirt
Metals,
Ltd.
(Exercise
Price
$0.25,
Exp.
Date
11/19/24)
(1)(3)
2,834,650‌
$
990,133‌
0.2‌
%
Canada
Arizona
Metals
Corp.
(Exercise
Price
$3.00,
Exp.
Date
4/22/22)
(1)(3)
1,200,000‌
2,085,405‌
0.4‌
Aya
Gold
&
Silver,
Inc.
(Exercise
Price
$3.30,
Exp.
Date
9/8/23)
(1)(3)
1,200,000‌
6,077,733‌
1.3‌
Benchmark
Metals,
Inc.
(Exercise
Price
$0.40,
Exp.
Date
12/23/21)
(1)(3)
5,000,000‌
2,700,693‌
0.6‌
Benchmark
Metals,
Inc.
(Exercise
Price
$1.80,
Exp.
Date
9/15/22)
(1)(3)
3,692,307‌
57,808‌
0.0‌
Bunker
Hill
Mining
Corp.
(Exercise
Price
$0.60,
Exp.
Date
2/9/26)
(1)(3)
1,250,000‌
9,785‌
0.0‌
Bunker
Hill
Mining
Corp.
(Exercise
Price
$0.50,
Exp.
Date
8/15/23)
(1)(3)
3,464,957‌
0‌
0.0‌ 
Bunker
Hill
Mining
Corp.
(Exercise
Price
$0.50,
Exp.
Date
8/15/23)
(1)(3)
9,500,000‌
0‌
0.0‌ 
Emerita
Resources
Corp.
(Exercise
Price
$1.50,
Exp.
Date
7/15/23)
(1)(3)
1,375,000‌
1,937,454‌
0.4‌
Euro
Sun
Mining,
Inc.
(Exercise
Price
$0.55,
Exp.
Date
6/5/23)
(1)(3)
5,500,000‌
43,055‌
0.0‌
Huntington
Exploration,
Inc.
(Exercise
Price
$0.40,
Exp.
Date
6/17/23)
(1)(3)
3,950,000‌
0‌
0.0‌ 
Huntsman
Exploration,
Inc.
(Exercise
Price
$0.35,
Exp.
Date
10/22/23)
(1)(3)
6,175,000‌
0‌
0.0‌ 
Sable
Resources,
Ltd.
(Exercise
Price
$0.20,
Exp.
Date
9/10/23)
(1)(3)
11,000,000‌
344,436‌
0.1‌
Total
diversified
metals
mining,
exploration,
development
and
royalty
companies
(Cost
$1,806,421)
1
4
,246,5
02‌
3
.
0‌
Gold
mining,
exploration,
development
and
royalty
companies
Canada
Desert
Gold
Ventures,
Inc.
(Exercise
Price
$0.40,
Exp.
Date
8/21/23)
(1)(3)
6,700,000‌
0‌
0.0‌ 
G
Mining
Ventures
Corp.
(Exercise
Price
$0.80,
Exp.
Date
5/25/22)
(1)(3)
5,421,982‌
636,657‌
0.1‌
G
Mining
Ventures
Corp.
(Exercise
Price
$1.90,
Exp.
Date
9/9/24)
(1)(3)
3,500,000‌
273,983‌
0.1‌
Maverix
Metals,
Inc.
(Exercise
Price
$3.30,
Exp.
Date
12/23/21)
(1)(3)
250,000‌
504,912‌
0.1‌
Mawson
Resources,
Ltd.
(Exercise
Price
$0.45,
Exp.
Date
5/20/22)
(1)(3)
4,300,000‌
0‌
0.0‌ 
Monarch
Mining
Corp.
(Exercise
Price
$1.05,
Exp.
Date
6/29/23)
(1)(3)
2,500,000‌
117,421‌
0.0‌
Nighthawk
Gold
Corp.
(Exercise
Price
$1.50,
Exp.
Date
7/7/23)
(1)(3)
2,174,000‌
17,018‌
0.0‌
O3
Mining,
Inc.
(Exercise
Price
$3.25,
Exp.
Date
6/18/22)
(1)(3)
740,000‌
0‌
0.0‌ 
Osino
Resources
Corp.
(Exercise
Price
$1.05,
Exp.
Date
1/30/22)
(1)(3)
1,000,000‌
109,593‌
0.0‌
Prime
Mining
Corp.
(Exercise
Price
$1.10,
Exp.
Date
6/10/25)
(1)(3)
920,000‌
2,599,867‌
0.5‌
Prime
Mining
Corp.
(Exercise
Price
$5.00,
Exp.
Date
4/27/24)
(1)(3)
400,000‌
241,105‌
0.1‌
Probe
Metals,
Inc.
(Exercise
Price
$1.30,
Exp.
Date
12/10/21)
(1)(3)
2,362,500‌
998,669‌
0.2‌
Pure
Gold
Mining,
Inc.
(Exercise
Price
$0.85,
Exp.
Date
7/18/22)
(1)(3)
1,500,000‌
105,679‌
0.0‌
Thesis
Gold,
Inc.
(Exercise
Price
$0.75,
Exp.
Date
10/31/22)
(1)(3)
2,000,000‌
861,091‌
0.2‌
Westhaven
Gold
Corp.
(Exercise
Price
$1.00,
Exp.
Date
2/4/23)
(1)(3)
2,750,000‌
0‌
0.0‌ 
Total
gold
mining,
exploration,
development
and
royalty
companies
(Cost
$2,213,098)
6
,
465
,
995‌
1.
3‌
Silver
mining,
exploration,
development
and
royalty
companies
Canada
Discovery
Silver
Corp.
(Exercise
Price
$0.77,
Exp.
Date
5/28/22)
(1)(3)
1,454,545‌
1,275,268‌
0.3‌
Discovery
Silver
Corp.
(Exercise
Price
$1.75,
Exp.
Date
8/7/22)
(1)(3)
975,000‌
198,442‌
0.1‌
Silver
Tiger
Metals,
Inc.
(Exercise
Price
$0.50,
Exp.
Date
7/31/23)
(1)(3)
1,666,666‌
156,562‌
0.0‌
Total
silver
mining,
exploration,
development
and
royalty
companies
(Cost
$137,059)
1,6
30
,
272‌
0.4‌
Total
warrants
(Cost
$4,156,578)
22,342,769‌
4.7‌
Money
Market
Fund
Federated
US
Treasury
Cash
Reserve
Fund
-
Institutional
Shares,
0.01%
(Cost
$6,337,406)
(4)
6,337,406‌
6,337,406‌
1.3‌ 
Investments,
at
value
(Cost
$261,674,792)
482,272,854‌
100.1‌
Cash,
receivables
and
other
assets
less
other
liabilities
(374,399‌)
(0.1‌)
Net
assets
$
481,898,455‌
100.0‌%
ADR
American
Depositary
Receipt
PLC
Public
Limited
Company
Schedule
of
Investments
(continued)
November
30,
2021
12
The
notes
to
financial
statements
form
an
integral
part
of
these
statements.
Portfolio
Statistics
(Unaudited)
Portfolio
statistics
(Unaudited)
November
30,
2021
*Geographic
breakdown,
which
is
based
on
company
domiciles,
is
expressed
as
a
percentage
of
total
net
assets
including
cash.
(1)
Non-income
producing
security.
(2)
Restricted
security.
(3)
Security
fair
valued
in
accordance
with
procedures
adopted
by
the
Board
of
Directors.
At
the
period
end,
the
value
of
these
securities
amounted
to
$22,492,500
or
4.7%
of
net
assets.
(4)
Dividend
yield
changes
daily
to
reflect
current
market
conditions.
Rate
was
the
quoted
yield
as
of
November
30,
2021.
Geographic
Breakdown*
Australia
14.8‌%
Canada
71.1‌ 
Cayman
Islands
4.2‌ 
South
Africa
7.7‌ 
United
Kingdom
1.0‌ 
Cash
1.2‌ 
100.0‌%
Schedule
of
Investments
(continued)
November
30,
2021
13
The
notes
to
financial
statements
form
an
integral
part
of
these
statements.
Statement
of
Assets
and
Liabilities
November
30,
2021
The
closing
price
of
the
Company’s
shares
on
the
New
York
Stock
Exchange
was
$20.70
on
November
30,
2021.
Assets
Investments,
at
value
(Cost
$261,674,792)
$
482,272,854‌
Cash
79,943‌
Foreign
currency
(Cost
$411)
401‌
Dividends
receivable,
net
of
withholding
taxes
payable
236,792‌
Prepaid
expenses
104,177‌
Total
assets
$
482,694,167‌
Liabilities
Accrued
investment
adviser
fees
276,001‌
Accrued
fund
service
fees
39,353‌
Liability
for
retirement
benefits
due
to
retired
directors
333,458‌
Other
expenses
146,900‌
Total
liabilities
795,
7
12‌
Net
assets
$
481,
898
,
455‌
Common
shares
$1
par
value
Authorized:
40,000,000
shares
Issued
and
Outstanding:
19,289,905
shares
$
19,289,905‌
Share
premium
(capital
surplus)
1,372,500‌
Distributable
earnings
461,
236
,
050‌
Net
assets
$
481,898,455‌
Net
asset
value
per
share
$
24.98‌
14
The
notes
to
financial
statements
form
an
integral
part
of
these
statements.
Statement
of
Operations
For
the
year
ended
November
30,
2021
Investment
income
Dividend
income
(net
of
withholding
taxes
of
$619,443)
$
2,673,970‌
Total
investment
income
2,673,970‌
Expenses
Lease
property
expense
(Note
8)
57,956‌
Investment
adviser
fees
3,361,800‌
Fund
services
fees
241,746‌
Compliance
services
fees
73,510‌
Transfer
agent
fees
33,800‌
Custodian
fees
125,000‌
Directors'
fees
and
expenses
181,413‌
Retired
directors'
fees
75,000‌
Insurance
fees
132,501‌
Legal
fees
108,333‌
Audit
fees
35,000‌
Shareholder
reports
and
proxy
expenses
31,865‌
Dues
and
listing
fees
25,000‌
Other
expenses
10,030‌
Total
expenses
4,492,954‌
Change
in
retirement
benefits
due
to
retired
directors
(36,334‌)
Investment
adviser
fees
waived
(95,530‌)
Net
expenses
4,361,090‌
Net
investment
loss
(1,687,120‌)
Net
realized
and
unrealized
gain
(loss)
from
investments
and
foreign
currency
transactions
Proceeds
from
sales
88,022,608‌
Cost
of
securities
sold
(61,590,514‌)
Net
realized
gain
from
investments
26,432,094‌
Net
realized
gain
(loss)
from
foreign
currency
transactions
Investments
44,945‌
Foreign
currency
(253,585‌)
Net
realized
loss
from
foreign
currency
transactions
(208,640‌)
Net
increase
in
unrealized
appreciation
(depreciation)
on
investments
Balance,
beginning
of
year
226,785,880‌
Balance,
end
of
year
220,598,062‌
Net
decrease
in
unrealized
appreciation
(depreciation)
on
investments
(6,187,818‌)
Net
unrealized
loss
on
translation
of
assets
and
liabilities
in
foreign
currency
(586‌)
Net
realized
and
unrealized
gain
(loss)
from
investments
and
foreign
currency
transactions
20,035,050‌
Net
increase
in
net
assets
resulting
from
operations
$
18,347,930‌
15
The
notes
to
financial
statements
form
an
integral
part
of
these
statements.
Statements
of
Changes
in
Net
Assets
Year
Ended
November
30,
2021
Year
Ended
November
30,
2020
Net
investment
loss
$
(1,687,120‌)
$
(2,573,199‌)
Net
realized
gain
26,432,094‌
35,275,757‌
Net
realized
gain
(loss)
from
foreign
currency
transactions
(208,640‌)
989,453‌
Net
increase
(decrease)
in
unrealized
appreciation
(depreciation)
on
investments
(6,187,818‌)
144,741,384‌
Net
unrealized
gain
(loss)
on
translation
of
assets
and
liabilities
in
foreign
currency
(586‌)
9,506‌
Net
increase
in
net
assets
resulting
from
operations
18,347,930‌
178,442,901‌
Dividends
paid/payable
(385,798‌)
(385,798‌)
Net
increase
in
net
assets
17,962,132‌
178,057,103‌
Net
assets,
beginning
of
year
463,936,323‌
285,879,220‌
Net
assets,
end
of
year
$
481,898,455‌
$
463,936,323‌
16
++++++++++++++++++++++
16
Notes
to
Financial
Statements
Year
ended
November
30,
2021
1.
Organization
ASA
Gold
and
Precious
Metals
Limited
(the
“Company”)
is
a
non-diversified,
closed-end
investment
company
registered
under
the
Investment
Company
Act
of
1940,
as
amended
(the
“1940
Act”).
The
Company
was
initially
organized
as
a
public
limited
liability
company
in
the
Republic
of
South
Africa
in
June
1958.
On
November
11,
2004,
the
Company’s
shareholders
approved
a
proposal
to
move
the
Company’s
place
of
incorporation
from
the
Republic
of
South
Africa
to
the
Commonwealth
of
Bermuda
by
reorganizing
itself
into
an
exempted
limited
liability
company
formed
in
Bermuda.
The
Company
is
registered
with
the
Securities
and
Exchange
Commission
(the
“SEC”)
pursuant
to
an
order
under
Section
7(d)
of
the
1940
Act.
The
Company
seeks
long-term
capital
appreciation
primarily
through
investing
in
companies
engaged
in
the
exploration
for,
development
of
projects
or
mining
of
precious
metals
and
minerals.
The
Company
is
managed
by
Merk
Investments
LLC
(the
“Adviser”).
2.
Summary
of
significant
accounting
policies
The
following
is
a
summary
of
the
significant
accounting
policies:
A.
Security
valuation
The
net
asset
value
of
the
Company
generally
is
determined
as
of
the
close
of
regular
trading
on
the
New
York
Stock
Exchange
(the
“NYSE”)
on
the
date
for
which
the
valuation
is
being
made
(the
“Valuation
Time”).
Portfolio
securities
listed
on
U.S.
and
foreign
stock
exchanges
generally
are
valued
at
the
last
reported
sale
price
as
of
the
Valuation
Time
on
the
exchange
on
which
the
securities
are
primarily
traded,
or
the
last
reported
bid
price
if
a
sale
price
is
not
available.
Securities
traded
over
the
counter
are
valued
at
the
last
reported
sale
price
or
the
last
reported
bid
price
if
a
sale
price
is
not
available.
Securities
listed
on
foreign
stock
exchanges
may
be
fair
valued
based
on
significant
events
that
have
occurred
subsequent
to
the
close
of
the
foreign
markets.
Shares
of
non-exchange
traded
open-end
mutual
funds
are
valued
at
net
asset
value
(“NAV”).
To
value
its
warrants,
the
Company's
valuation
committee
typically
utilizes
the
Black-
Scholes
model
using
the
listed
price
for
the
underlying
common
shares.
The
valuation
is
a
combination
of
value
of
the
stock
price
less
the
exercise
price,
plus
some
value
related
to
the
volatility
of
the
stock
over
the
remaining
time
period
prior
to
expiration.
Securities
for
which
current
market
quotations
are
not
readily
available
are
valued
at
their
fair
value
as
determined
in
accordance
with
procedures
approved
by
the
Company’s
Board
of
Directors.
If
a
security
is
valued
at
a
“fair
value,”
that
value
may
be
different
from
the
last
quoted
price
for
the
security.
Various
factors
may
be
reviewed
in
order
to
make
a
good
faith
determination
of
a
security’s
fair
value.
These
factors
include,
but
are
not
limited
to,
the
nature
of
the
security;
relevant
financial
or
business
developments
of
the
issuer;
actively
traded
similar
or
related
securities;
conversion
rights
on
the
security;
and
changes
in
overall
market
conditions.
The
difference
between
cost
and
market
value
is
reflected
separately
as
net
unrealized
appreciation
(depreciation)
on
investments.
The
net
realized
gain
or
loss
from
the
sale
of
securities
is
determined
for
accounting
purposes
on
the
identified
cost
basis.
B.
Restricted
securities
At
November
30,
2021,
the
Company
held
investments
in
restricted
securities
of
0.18
%
of
net
assets
valued
in
accordance
with
procedures
approved
by
the
Company’s
Board
of
Directors
as
follows:
C.
Fair
value
measurement
In
accordance
with
accounting
principles
generally
accepted
in
the
United
States
of
America
(“U.S.
GAAP”),
fair
value
is
defined
as
the
price
that
the
Company
would
receive
to
sell
an
investment
or
pay
to
transfer
a
liability
in
a
timely
transaction
with
an
independent
buyer
in
the
principal
market,
or
in
the
absence
of
a
principal
market
the
most
advantageous
market
for
the
investment
or
liability.
U.S.
GAAP
establishes
a
three-tier
hierarchy
to
distinguish
between
(1)
inputs
that
reflect
the
assumptions
market
participants
would
use
in
pricing
an
asset
or
liability
developed
based
on
market
data
obtained
from
sources
independent
of
the
reporting
entity
(observable
inputs)
and
(2)
inputs
that
reflect
the
reporting
entity’s
own
assumptions
about
the
assumptions
market
participants
would
use
in
pricing
an
asset
or
liability
developed
based
on
the
best
information
available
in
the
circumstances
(unobservable
inputs)
and
to
establish
Shares
Cost
Issuer
Value
per
Unit
Value
Acquisition
Date
1,071,400
$2,142,800
Americas
Gold
&
Silver
Corp.
$0.8099
$867,727
5/7/20
17
Notes
to
Financial
Statements
(continued)
Year
ended
November
30,
2021
classification
of
fair
value
measurements
for
disclosure
purposes.
Various
inputs
are
used
in
determining
the
value
of
the
Company’s
investments.
The
inputs
are
summarized
in
the
three
broad
levels
listed
below.
Level
1
Unadjusted
quoted
prices
in
active
markets
for
identical
assets
or
liabilities
that
the
Company
has
the
ability
to
access.
Level
2
Observable
inputs
other
than
quoted
prices
included
in
level
1
that
are
observable
for
the
asset
or
liability
either
directly
or
indirectly.
These
inputs
may
include
quoted
prices
for
identical
instruments
on
an
inactive
market,
prices
for
similar
investments,
interest
rates,
prepayment
speeds,
credit
risk,
yield
curves,
default
rates,
and
similar
data.
Level
3
Unobservable
inputs
for
the
assets
or
liability
to
the
extent
that
relevant
observable
inputs
are
not
available,
representing
the
Company’s
own
assumptions
about
the
assumptions
that
a
market
participant
would
use
in
valuing
the
asset
or
liability,
and
that
would
be
based
on
the
best
information
available.
The
inputs
or
methodology
used
for
valuing
securities
are
not
necessarily
an
indication
of
the
risk
associated
with
investing
in
those
securities.
The
following
is
a
summary
of
the
inputs
used
as
of
November
30
,
2021
in
valuing
the
Company’s
investments
at
fair
value:
Investment
in
Securities
(1)
Measurements
at
November
30,
2021
Level
1
Level
2
Level
3
Total
Common
Shares
Gold
mining,
exploration,
development
and
royalty
companies
$
344,782,256
$
$
$
344,782,256
Diversified
metals
mining,
exploration,
development
and
royalty
companies
89,223,295
89,223,295
Silver
mining,
exploration,
development
and
royalty
companies
19,437,397
19,437,397
Rights
Silver
mining,
exploration,
development
and
royalty
companies
149,731
149,731
Warrants
Diversified
metals
mining,
exploration,
development
and
royalty
companies
14,246,502
14,246,502
Gold
mining,
exploration,
development
and
royalty
companies
6,465,995
6,465,995
Silver
mining,
exploration,
development
and
royalty
companies
1,630,272
1,630,272
Money
Market
Fund
6,337,406
6,337,406
Total
Investments
$
4
59
,
780
,
354
$
$
22
,
492
,
500
$
4
82
,
272
,
854
(1)
See
schedule
of
investments
for
country
classifications.
2.
Summary
of
significant
accounting
policies
(continued)
C.
Fair
value
measurement
(continued)
18
Notes
to
Financial
Statements
(continued)
Year
ended
November
30,
2021
The
following
is
a
reconciliation
of
Level
3
investments
for
which
significant
unobservable
inputs
were
used
to
determine
fair
value.
*
The
change
in
unrealized
appreciation/(depreciation)
is
included
in
net
change
in
unrealized
appreciation/(depreciation)
of
investments
in
the
accompanying
Statement
of
Operations.
Significant
unobservable
inputs
developed
by
the
Valuation
Committee
(“Valuation
Committee”)
for
Level
3
investments
held
at
November
30,
2021
are
as
follows:
1
Fair
valued
rights
are
valued
based
on
the
specifics
of
the
rights
at
a
discount
to
the
market
price
of
the
underlying
security.
2
Warrants
are
priced
based
on
the
Black
Scholes
Method;
the
key
input
to
this
method
is
modeled
volatility
of
the
investment;
the
lower
the
modeled
volatility,
the
lower
the
valuation
of
the
warrant.
D.
Foreign
Currency
Translation
Portfolio
securities
and
other
assets
and
liabilities
denominated
in
foreign
currencies
are
translated
into
U.S.
dollar
amounts
at
the
rate
of
exchange
reported
by
independent
data
providers.
Purchases
and
sales
of
investment
securities
and
income
and
expense
items
denominated
in
foreign
currencies
are
translated
into
U.S.
dollar
amounts
on
the
respective
dates
of
such
transactions.
The
portion
of
the
results
arising
from
changes
in
the
exchange
rates
and
the
portion
due
to
fluctuations
arising
from
changes
in
the
market
prices
of
securities
are
not
isolated.
The
resulting
net
foreign
currency
gain
or
loss
is
included
on
the
Statements
of
Operations.
Realized
foreign
currency
gains
or
losses
arise
from
sales
of
foreign
currencies,
currency
gains
or
losses
realized
between
the
trade
and
settlement
dates
on
securities
transactions
and
the
difference
between
the
amounts
of
dividends,
interest,
and
foreign
withholding
taxes
recorded
on
the
Company’s
books
and
the
U.S.
dollar
equivalent
of
the
amounts
actually
received
or
paid.
E.
Securities
Transactions
and
Investment
Income
During
the
year
ended
November
30,
2021,
sales
and
purchases
of
portfolio
securities
(other
than
temporary
short-term
investments)
amounted
to
$86,792,341
and
$79,367,697,
respectively.
As
of
November
30,
2021,
a
significant
portion
of
the
Company’s
assets
consisted
of
securities
of
junior
and
intermediate
mining
company
issuers.
Dividend
income
is
recorded
on
the
ex-dividend
date,
net
of
withholding
taxes
or
ADR
fees,
if
any.
Interest
income
is
recognized
on
the
accrual
basis.
Common
Stock
Rights
Warrants
Balance
November
30,
2020
$
770,001
$
173,123
$
11,181,970
Purchases
-
-
1,255
,
755
Sales
-
-
(
567,029
)
Realized
gain
-
-
(
113,697
)
Transfers
out
(770,001)
-
-
Net
change
in
unrealized
appreciation
(depreciation)
-
(
23
,
392
)
10,585,770
Balance
November
30,
2021
$
-
$
1
49
,
731
$
22
,
342
,
769
Net
change
in
unrealized
appreciation
(depreciation)
from
investments
held
as
of
November
30,
2021*
$
-
$
(
23,392
)
$
1
0,585,770
Asset
Categories
Fair
Value
Valuation
Technique(s)
Unobservable
Input
Range
(Weighted
Average)
Rights
1
$
1
49
,
731
Market
transaction
Discount
70%
(70%)
Warrants
2
2
2,342,769
Black
Scholes
Method
Volatility
20
%
-
50
%
(
37
%)
2.
Summary
of
significant
accounting
policies
(continued)
C.
Fair
value
measurement
(continued)
19
Notes
to
Financial
Statements
(continued)
Year
ended
November
30,
2021
F.
Dividends
to
Shareholders
Dividends
to
shareholders
are
recorded
on
the
ex-dividend
date.
The
reporting
for
financial
statement
purposes
of
dividends
paid
from
net
investment
income
and/or
net
realized
gains
may
differ
from
their
ultimate
reporting
for
U.S.
federal
income
tax
purposes,
primarily
because
of
the
separate
line
item
reporting
for
financial
statement
purposes
of
foreign
exchange
gains
or
losses.
G.
Use
of
Estimates
The
preparation
of
the
financial
statements
in
conformity
with
U.S.
GAAP
requires
management
to
make
estimates
and
assumptions
that
affect
amounts
reported
in
the
financial
statements
and
accompanying
notes.
Actual
results
could
differ
from
those
estimates.
It
is
management’s
opinion
that
all
adjustments
necessary
for
a
fair
statement
of
the
results
of
the
interim
periods
presented
have
been
made.
All
adjustments
are
of
a
normal
recurring
nature.
H.
Basis
of
Presentation
The
financial
statements
are
presented
in
U.S.
dollars.
The
Company
is
an
investment
company
and
accordingly
follows
the
investment
company
accounting
and
reporting
guidance
of
the
Financial
Accounting
Standards
Board
(“FASB”)
Accounting
Standard
Codification,
Topic
946
“Financial
Services
-
Investment
Companies”.
I.
Income
Taxes
In
accordance
with
U.S.
GAAP
requirements
regarding
accounting
for
uncertainties
on
income
taxes,
management
has
analyzed
the
Company’s
tax
positions
taken
on
federal
and
state
income
tax
returns,
as
applicable,
for
all
open
tax
years
(2018-2021).
As
of
November
30,
2021,
the
Company
has
not
recorded
any
unrecognized
tax
benefits.
The
Company’s
policy,
if
it
had
unrecognized
benefits,
is
to
recognize
accrued
interest
and
penalties
in
operating
expenses.
3.
Tax
status
of
the
Company
The
Company
is
a
“passive
foreign
investment
company”
(“PFIC”)
for
U.S.
federal
income
tax
purposes
and
is
not
subject
to
Bermuda
tax
as
an
exempted
limited
liability
company
organized
under
the
laws
of
Bermuda.
Nor
is
the
Company
generally
subject
to
U.S.
federal
income
tax,
since
it
is
a
non-U.S.
corporation
whose
only
business
activity
in
the
United
States
is
trading
in
stocks
or
securities
for
its
own
account;
under
the
U.S.
federal
tax
law
that
activity
does
not
constitute
engaging
in
the
conduct
of
a
trade
or
business
within
the
United
States,
even
if
its
principal
office
is
located
therein.
As
a
result,
its
gross
income
is
not
subject
to
U.S.
federal
income
tax,
though
certain
types
of
income
it
earns
from
U.S.
sources
(such
as
dividends
of
U.S.
payors)
are
subject
to
U.S.
federal
withholding
tax.
4.
Fees
and
Expenses
and
Other
Transactions
with
Affiliates
Investment
Adviser
Merk
Investments
LLC
(the
“Adviser”)
is
the
investment
adviser
to
the
Company.
Pursuant
to
an
investment
advisory
agreement,
the
Adviser
receives
an
advisory
fee,
payable
monthly,
from
the
Company
at
an
annual
rate
of
0.70%
of
the
Company’s
average
daily
net
assets.
Effective
December
1,
2020,
the
Adviser
voluntarily
agreed
to
waive
a
portion
of
its
advisory
fee,
equal
to
an
annual
rate
of
0.05%
of
the
Company’s
net
assets
exceeding
$300
million,
and
an
additional
0.10%
of
the
Company’s
net
assets
exceeding
$500
million.
The
Adviser
waived
$95,530
for
the
year
ended
November
30,
2021.
Other
Service
Providers
Apex
US
Holdings
LLC
(d/b/a
Apex
Fund
Services)
(“Apex”)
provides
fund
accounting,
fund
administration
and
compliance
services
to
the
Company.
The
fees
related
to
these
services
are
included
in
fund
services
fees
within
the
Statement
of
Operations.
Apex
also
provides
certain
shareholder
report
production
and
EDGAR
conversion
and
filing
services.
Pursuant
to
an
Apex
services
agreement,
the
Company
pays
Apex
customary
fees
for
its
services.
Apex
provides
a
Principal
Financial
Officer,
as
well
as
certain
additional
compliance
support
functions.
Foreside
Fund
Services,
LLC
provides
a
Chief
Compliance
Officer
to
the
Company.
5.
Exemptive
order
The
Company
is
a
closed-end
investment
company
and
operates
pursuant
to
an
exemptive
order
issued
by
the
Securities
and
Exchange
Commission
(the
“SEC”)
pursuant
to
Section
7(d)
of
the
1940
Act
(the
“Order”).
The
Order
is
conditioned
upon,
among
other
things,
the
Company
complying
with
certain
requirements
relating
to
the
custody
of
assets
and
settlement
of
securities
transactions
outside
of
the
United
States
different
than
those
required
of
other
registered
investment
companies.
These
conditions
make
it
more
difficult
for
the
Company
to
implement
a
flexible
investment
strategy
and
to
fully
achieve
its
desired
portfolio
diversification
than
if
it
were
not
subject
to
such
requirements.
2.
Summary
of
significant
accounting
policies
(continued)
20
Notes
to
Financial
Statements
(continued)
Year
ended
November
30,
2021
6.
Retirement
plans
The
Company
has
recorded
a
liability
for
retirement
benefits
due
to
retired
directors.
The
liability
for
these
benefits
at
November
30,
2021
was
$
333,458
.
A
director
whose
first
election
to
the
Board
of
Directors
was
prior
to
January
1,
2008
qualifies
to
receive
retirement
benefits
if
he
has
served
the
Company
(and
any
of
its
predecessors)
for
at
least
twelve
years
prior
to
retirement.
Directors
first
elected
on
or
after
January
1,
2008
are
not
eligible
to
participate
in
the
plan.
7.
Indemnifications
In
the
ordinary
course
of
business,
the
Company
enters
into
contracts
that
contain
a
variety
of
indemnification
pro-
visions.
The
Company’s
maximum
exposure
under
these
arrangements
is
unknown.
8.
Operating
lease
commitment
In
June
2017,
the
Company
entered
into
a
three-year
operating
lease
agreement,
commencing
March
1,
2018,
in
San
Mateo,
CA
for
approximately
2,500
square
feet
to
be
used
as
office
space
for
its
employees.
The
lease
was
terminated
as
of
February
28,
2021.
9.
Share
repurchase
The
Company
may
from
time
to
time
purchase
its
common
shares
at
a
discount
to
NAV
on
the
open
market
in
such
amounts
and
at
such
prices
as
the
Company
may
deem
advisable.
The
Company
had
19,289,905
shares
outstanding
as
of
November
3
0
,
2021
.
There
were
no
repurchases
during
the
year
ended
November
3
0
,
2021
.
10.
Subsequent
events
In
accordance
with
U.S.
GAAP
provisions,
management
has
evaluated
the
possibility
of
subsequent
events
existing
in
the
Company’s
financial
statements
through
the
date
the
financial
statements
were
issued.
The
Company
believes
that
there
are
no
material
events
that
would
require
disclosure.
21
Financial
Highlights
Years
ended
November
30,
Per
share
operating
performance
(1)
2021
2020
2019
2018
2017
Net
asset
value,
beginning
of
year
$24.05
$14.82
$10.10
$12.66
$12.61
Net
investment
loss
(0.09)
(0.13)
(0.06)
(0.07)
(0.09)
Net
realized
gain
(loss)
from
investments
1.37
1.83
0.09
(0.47)
(0.36)
Net
realized
gain
(loss)
from
foreign
currency
transactions
(0.01)
0.05
(0.06)
0.01
0.01
Net
increase
(decrease)
in
unrealized
appreciation
on
investments
(0.32)
7.50
4.77
(2.00)
0.53
Net
unrealized
gain
on
translation
of
assets
and
liabilities
in
foreign
currency
0.00
0.00
0.00
0.00
0.00
Net
increase
(decrease)
in
net
assets
resulting
from
operations
0.95
9.25
4.74
(2.53)
0.09
Dividends
From
net
investment
income
–‌
(0.02)
(0.02)
(0.03)
(0.04)
From
net
realized
gain
on
investments
(0.02)
–‌
–‌
–‌
–‌
Net
asset
value,
end
of
year
$24.98
$24.05
$14.82
$10.10
$12.66
Market
value
per
share,
end
of
year
$20.70
$19.91
$12.20
$8.66
$11.05
Total
investment
return
Based
on
market
price
(2)
4.06%
63.38%
41.14%
(21.39)%
2.57%
Based
on
net
asset
value
(3)
3.96%
62.46%
47.01%
(19.97)%
0.74%
Ratio
of
average
net
assets
Expenses
(4)
0.94%
1.02%
1.38%
1.35%
1.19%
Net
expenses
0.91%
1.02%
1.38%
1.35%
1.19%
Net
investment
loss
(0.35)%
(0.67)%
(0.44)%
(0.63)%
(0.65)%
Supplemental
data
Net
assets,
end
of
period
(000
omitted)
$481‌,898
$463‌,936
$285‌,879
$194‌,834
$244‌,202
Portfolio
turnover
rate
17‌%
31‌%
45‌%
3‌%
9‌%
Shares
outstanding
(000
omitted)
19‌,290
19‌,290
19‌,290
19‌,290
19‌,290
(1)
Per
share
amounts
from
operations
have
been
calculated
using
the
average
shares
method.
(2)
Total
investment
return
is
calculated
assuming
a
purchase
of
shares
at
the
current
market
price
at
close
the
day
before
and
a
sale
at
the
current
market
price
on
the
last
day
of
each
period
reported.
Dividends
are
assumed,
for
purposes
of
this
calculation,
to
be
reinvested
at
prices
obtained
under
the
Company’s
dividend
reinvestment
plan.
(3)
Total
investment
return
is
calculated
assuming
a
purchase
of
shares
at
the
current
net
asset
value
at
close
the
day
before
and
a
sale
at
the
current
net
asset
value
on
the
last
day
of
each
period
reported.
Dividends
are
assumed,
for
purposes
of
this
calculation,
to
be
reinvested
at
prices
obtained
under
the
Company’s
dividend
reinvestment
plan.
(4)
Reflects
the
expense
ratio
excluding
any
waivers.
22
Certain
Tax
Information
for
U.S.
Shareholders
(Unaudited)
Certain
tax
information
for
U.S.
shareholders
(Unaudited)
The
Company
is
a
“passive
foreign
investment
company”
(“PFIC”)
for
U.S.
federal
income
tax
purposes.
In
view
of
this,
U.S.
investors
holding
common
shares
in
taxable
accounts
are
strongly
urged
to
review
the
important
tax
information
regarding
the
consequences
of
an
investment
in
the
common
shares
of
the
Company,
which
may
be
found
at
www.
asaltd.com
under
“Investor
Information
|
Taxpayer
Information
-
PFIC”.
Due
to
the
complexity
and
potentially
adverse
effect
of
the
applicable
tax
rules,
U.S.
shareholders
are
strongly
urged
to
consult
their
own
tax
advisors
concerning
the
impact
of
these
rules
on
their
investment
in
the
Company
and
on
their
individual
situations,
and
any
additional
informational
filing
requirements.
Dividend
Reinvestment
and
Stock
Purchase
Plan
(Unaudited)
Dividend
reinvestment
and
stock
purchase
plan
(Unaudited)
Computershare
Trust
Company,
N.A.
(“Computershare”)
has
been
authorized
by
the
Company
to
offer
and
administer
the
Computershare
Investment
Plan,
a
dividend
reinvestment
and
stock
purchase
plan
(“CIP”)
to
shareholders
as
well
as
new
investors
or
non-shareholders.
Shareholders
and
new
investors
may
elect
to
participate
in
the
CIP
by
signing
an
enrollment
form
or
by
going
to
www.computershare.com/investor
and
following
the
instructions.
New
investors
or
non-shareholders
must
include
a
minimum
initial
investment
of
at
least
$500.
Computershare
as
agent
will
apply
to
the
purchase
of
common
shares
of
the
Company
in
the
open
market
(i)
all
cash
dividends
(after
deduction
of
the
service
charge
described
below)
that
become
payable
to
such
participant
on
the
Company’s
shares
(including
shares
registered
in
his
or
her
name
and
shares
accumulated
under
the
CIP)
and
(ii)
any
optional
cash
purchases
($50
minimum,
subject
to
an
annual
maximum
of
$250,000)
received
from
such
participant.
Computershare
may
combine
CIP
participant
purchase
requests
with
other
purchase
requests
received
from
other
CIP
participants
and
may
submit
the
combined
purchase
requests
in
bulk
to
Computershare’s
broker
as
a
single
purchase
order.
Purchase
requests
may
be
combined,
at
Computershare’s
discretion,
according
to
one
or
more
factors
such
as
purchase
type
(e.g.,
dividend
reinvestment,
one-time
ACH,
check,
etc.),
request
date,
or
request
delivery
method
(e.g.,
online,
regular
mail,
etc.).
Computershare
will
submit
bulk
purchase
orders
to
its
broker
as
and
when
required
under
the
terms
of
the
CIP.
Computershare’s
broker
may
execute
each
bulk
purchase
order
in
one
or
more
transactions
over
one
or
more
days,
depending
on
market
conditions.
Each
participant
whose
purchase
request
is
included
in
each
bulk
purchase
order
will
receive
the
weighted
average
market
price
of
all
shares
purchased
by
Computershare’s
broker
for
such
order.
Any
stock
dividends
or
split
shares
distributed
on
shares
held
in
the
CIP
will
be
credited
to
the
participant’s
account.
A
one-time
$10
enrollment
fee
to
establish
a
new
account
for
a
new
investor
or
non-shareholder
will
be
deducted
from
the
purchase
amount.
For
each
participant,
each
dividend
reinvestment
will
entail
a
transaction
fee
of
5%
of
the
amount
reinvested,
up
to
a
maximum
of
$3
plus
$0.03
per
share
purchased.
Each
optional
cash
purchase
by
check
or
one-time
online
bank
debit
will
entail
a
transaction
fee
of
$5
plus
$0.03
per
share
purchased.
If
a
participant
has
funds
automatically
deducted
monthly
from
his
or
her
savings
or
checking
account,
for
each
debit
the
transaction
fee
is
$2.50
plus
$0.03
per
share
purchased.
Fees
will
be
deducted
from
the
purchase
amount.
Each
batch
order
sale
will
entail
a
transaction
fee
of
$15
plus
$0.12
per
share
sold.
Each
market
order
sale
will
entail
a
transaction
fee
of
$25
plus
$0.12
per
share
sold.
Fees
are
deducted
from
the
proceeds
derived
from
the
sale.
All
per
share
fees
include
any
brokerage
commissions
Computershare
is
required
to
pay.
Any
fractional
share
will
be
rounded
up
to
a
whole
share
for
purposes
of
calculating
the
per
share
fee.
Additional
fees
are
charged
by
Computershare
for
specific
shareholder
requests
such
as
copies
of
account
statements
for
prior
years
($10
per
year
requested)
and
a
returned
check
and
ACH
reject
fee
of
$25.
Participation
in
the
CIP
may
be
terminated
by
a
participant
at
any
time
by
written,
telephone
or
Internet
instructions
to
Computershare.
Upon
termination,
a
participant
will
receive
a
certificate
for
the
whole
number
of
shares
credited
to
his
or
her
account,
unless
he
or
she
requests
the
sale
of
all
or
part
of
such
shares.
Dividends
reinvested
by
a
shareholder
under
the
CIP
will
generally
be
treated
for
U.S.
federal
income
tax
purposes
in
the
same
manner
as
dividends
paid
to
such
shareholder
in
cash.
See
“Certain
Tax
Information
for
U.S.
Shareholders”
for
more
information
regarding
tax
consequences
of
an
investment
in
shares
of
the
Company,
including
the
effect
of
the
Company’s
status
as
a
PFIC.
The
amount
of
the
service
charge
is
deductible
for
U.S.
federal
income
tax
purposes,
subject
to
limitations.
To
participate
in
the
CIP,
shareholders
may
not
hold
their
shares
in
a
“street
name”
brokerage
account.
Additional
information
regarding
the
CIP
may
be
obtained
from
Computershare,
P.O.
Box
505000,
Louisville,
KY
40233-5000.
Information
may
also
be
obtained
on
the
Internet
at
www.computershare.com/investor
or
by
calling
Computershare’s
Telephone
Response
Center
at
(800)
317-4445
between
9:00
a.m.
and
5:00
p.m.,
Eastern
time,
Monday
through
Friday.
23
Privacy
Notice
(Unaudited)
Privacy
notice
(Unaudited)
The
Company
is
committed
to
protecting
the
financial
privacy
of
its
shareholders.
We
do
not
share
any
nonpublic,
personal
information
that
we
may
collect
about
shareholders
with
anyone,
including
our
affiliates,
except
to
service
and
administer
shareholders’
share
accounts,
to
process
transactions,
to
comply
with
shareholders’
requests
of
legal
requirements
or
for
other
limited
purposes
permitted
by
law.
For
example,
the
Company
may
disclose
a
shareholder’s
name,
address,
social
security
number
and
the
number
of
shares
owned
to
its
administrator,
transfer
agent
or
other
service
providers
in
order
to
provide
the
shareholder
with
proxy
statements,
tax
reporting
forms,
annual
reports
or
other
information
about
the
Company.
This
policy
applies
to
all
of
the
Company’s
shareholders
and
former
shareholders.
We
keep
nonpublic
personal
information
in
a
secure
environment.
We
restrict
access
to
nonpublic
personal
information
to
Company
employees,
agents
and
service
providers
who
have
a
need
to
know
the
information
based
on
their
role
in
servicing
or
administering
shareholders’
accounts.
The
Company
also
maintains
physical,
electronic
and
procedural
safeguards
to
protect
the
confidentiality
of
nonpublic
personal
information.
Form
N-PX/Proxy
Voting
(Unaudited)
Form
N-PX/proxy
voting
(Unaudited)
The
company
files
a
list
of
its
proxy
votes
with
the
SEC
for
the
period
of
July
1
-
June
30
of
each
year
on
Form
N-PX.
The
policies
and
procedures
used
by
the
Company
to
determine
how
to
vote
proxies
relating
to
portfolio
securities
and
information
regarding
how
the
Company
voted
proxies
relating
to
portfolio
securities
during
the
most
recent
twelve
month
period
are
available
on
the
Company’s
website
at
www.asaltd.com
and
on
the
SEC’s
website
at
www.sec.gov
.
A
written
copy
of
the
Company’s
policies
and
procedures
is
available
without
charge,
upon
request,
by
calling
(800)
432-3378.
Form
N-PORT/Portfolio
Holdings
(Unaudited)
Form
N-PORT/portfolio
holdings
(Unaudited)
The
Company
files
its
complete
schedule
of
portfolio
holdings
with
the
SEC
for
the
first
and
third
quarters
of
each
fiscal
year
on
Form
N-PORT.
The
Company’s
Forms
N-PORT
are
available
on
the
SEC’s
website
at
www.sec.gov
.
The
Company’s
Forms
N-PORT
also
may
be
reviewed
and
copied
at
the
Reference
Room
in
Washington,
D.C.;
information
on
the
operation
of
the
Public
Reference
Room
may
be
obtained
by
calling
1-800-SEC-0330.
The
schedule
of
portfolio
holdings
on
Form
N-PORT
also
is
included
in
the
Company’s
financial
statements
for
the
first
and
third
quarters
of
each
fiscal
year
which
are
available
on
the
Company’s
website
at
www.asaltd.com
.
Share
Repurchase
(Unaudited)
Share
repurchase
(Unaudited)
Notice
is
hereby
given
in
accordance
with
Section
23(c)
of
the
1940
Act
that
the
Company
is
authorized
to
purchase
its
common
shares
in
the
open
market
if
the
discount
to
net
asset
value
exceeds
a
certain
threshold
as
determined
by
the
Board
of
Directors
from
time
to
time.
The
Company
may
purchase
its
common
shares
in
such
amounts
and
at
such
prices
as
the
Company
may
deem
advisable.
There
can
be
no
assurance
that
such
action
will
reduce
the
discount.
There
were
no
repurchases
during
the
six
months
ended
November
3
0
,
20
2
1
.
The
Company
had
19,289,905
shares
outstanding
on
November
3
0
,
20
2
1
.
Company
Investment
Objective,
Investment
Strategy
and
Risks
(Unaudited)
Company
investment
objective,
investment
strategy
and
risks
(Unaudited)
Investment
Objective
The
Company’s
investment
objective
is
long-term
capital
appreciation
through
investment
primarily
in
companies
engaged
in
the
exploration
for,
development
of
projects
or
mining
of
precious
metals
and
minerals.
Investment
Strategy
It
is
a
fundamental
policy
of
the
Company
that
at
least
80%
of
its
total
assets
must
be
(i)
invested
in
common
shares
or
securities
convertible
into
common
shares
of
companies
engaged,
directly
or
indirectly,
in
the
exploration,
mining
or
processing
of
gold,
silver,
platinum,
diamonds
or
other
precious
minerals,
(ii)
held
as
bullion
or
other
direct
forms
of
gold,
silver,
platinum
or
other
precious
minerals,
(iii)
invested
in
instruments
representing
interests
in
gold,
silver,
platinum
or
other
precious
minerals
such
as
certificates
of
deposit
therefor,
and/or
(iv)
invested
in
securities
of
investment
companies,
including
exchange
traded
funds,
or
other
securities
that
seek
to
replicate
the
price
movement
of
gold,
silver
or
platinum
bullion.
The
Company
employs
bottom-up
fundamental
analysis
and
relies
on
detailed
primary
research
including
meetings
with
company
executives,
site
visits
to
key
operating
assets,
and
proprietary
financial
analysis
in
making
its
investment
decisions.
24
Risks
The
following
discussion
summarizes
certain
(but
not
all)
of
the
principal
risks
associated
with
investing
in
the
Company.
The
Company
may
be
subject
to
other
risks
in
addition
to
those
identified
below,
such
as
the
risks
associated
with
its
tax
status
as
a
PFIC
(see
Note
3)
and
its
reliance
on
an
SEC
exemptive
order
(see
Note
5).
The
risk
factors
set
forth
in
the
following
are
described
in
no
particular
order
and
the
order
of
the
risk
factors
is
not
necessarily
indicative
of
significance.
The
relative
importance
of,
or
potential
exposure
as
a
result
of,
each
of
these
risks
will
vary
based
on
market
and
other
investment-specific
considerations.
Concentration
Risk.
The
Company
invests
at
least
80%
of
its
total
assets
in
securities
of
companies
engaged,
directly
or
indirectly,
in
the
exploration,
mining
or
processing
of
gold
or
other
precious
minerals.
The
Company
currently
is
invested
in
a
limited
number
of
securities
and
thus
holds
large
positions
in
certain
securities.
Because
the
Company’s
investments
are
concentrated
in
a
limited
number
of
securities
of
companies
involved
in
the
holding
or
mining
of
gold
and
other
precious
minerals
and
related
activities,
the
net
asset
value
of
the
Company
may
be
subject
to
greater
volatility
than
that
of
a
more
broadly
diversified
investment
company.
Gold
and
Precious
Metals/Minerals
Risk.
The
Company
invests
in
securities
that
typically
respond
to
changes
in
the
price
of
gold
and
other
precious
metals,
which
can
be
influenced
by
a
variety
of
global
economic,
financial,
and
political
factors;
increased
environmental
and
labor
costs
in
mining;
and
changes
in
laws
relating
to
mining
or
gold
production
or
sales;
and
the
price
may
fluctuate
substantially
over
short
periods
of
time.
Foreign
Securities
Risk/Emerging
Markets
Risk.
The
Company’s
returns
and
share
prices
may
be
affected
to
a
large
degree
by
several
factors,
including
fluctuations
in
currency
exchange
rates;
political,
social
or
economic
instability;
the
rule
of
law
with
respect
to
the
recognition
and
protection
of
property
rights;
and
less
stringent
accounting,
disclosure
and
financial
reporting
requirements
in
a
particular
country.
These
risks
are
generally
intensified
in
emerging
markets.
The
Company’s
share
prices
will
reflect
the
movements
of
the
different
stock
markets
in
which
it
is
invested
and
the
currencies
in
which
its
investments
are
denominated.
Geographic
Investment
Risk.
To
the
extent
that
the
Company
invests
a
significant
portion
of
its
assets
in
the
securities
of
companies
of
a
single
country
or
region,
it
is
more
likely
to
be
impacted
by
events
or
conditions
affecting
that
country
or
region.
As
of
November
30,
2021,
a
significant
portion
of
the
Company’s
assets
consisted
of
securities
of
Canadian
issuers.
Canada
Risk.
The
Canadian
economy
is
susceptible
to
adverse
changes
in
certain
commodities
markets,
including
those
related
to
the
natural
resources
and
mining
industries.
It
is
also
heavily
dependent
on
trading
with
key
partners.
Any
adverse
events
that
affect
Canada’s
major
industries
may
have
a
negative
impact
on
the
overall
Canadian
economy
and
the
Company’s
investments
in
Canadian
issuers.
Junior
and
Intermediate
Mining
Companies
Risk.
The
securities
of
junior
and
intermediate
exploration
and
development,
gold
and
silver
mining
companies,
which
are
often
more
speculative
in
nature,
tend
to
be
less
liquid
and
more
volatile
in
price
than
securities
of
larger
companies.
Private
Placement
Risk.
Privately
issued
securities,
including
those
which
may
be
sold
only
in
accordance
with
Rule
144A
under
the
Securities
Act
of
1933,
as
amended,
are
restricted
securities
that
are
not
registered
with
the
U.S.
Securities
and
Exchange
Commission.
The
liquidity
of
the
market
for
specific
privately
issued
securities
may
vary.
Accordingly,
the
Company
may
not
be
able
to
redeem
or
resell
its
interests
in
a
privately
issued
security
at
an
advantageous
time
or
at
an
advantageous
price,
which
may
result
in
a
loss
to
the
Company.
Restricted
Security
Risk.
The
Company
may
make
direct
equity
investments
in
securities
that
are
subject
to
contractual
and
regulatory
restrictions
on
transfer.
These
investments
may
involve
a
high
degree
of
business
and
financial
risk.
The
restrictions
on
transfer
may
cause
the
Company
to
hold
a
security
at
a
time
when
it
may
be
beneficial
to
liquidate
the
security,
and
the
security
could
decline
significantly
in
value
before
the
Company
could
liquidate
the
security.
Depositary
Receipts
Risk.
Depositary
receipts
risks
include,
but
are
not
limited
to,
fluctuations
in
foreign
currencies
and
foreign
investment
risks,
such
as
political
and
financial
instability,
less
liquidity
and
greater
volatility,
lack
of
uniform
accounting
auditing
and
financial
reporting
standards
and
increased
price
volatility.
In
addition,
depositary
receipts
may
not
track
the
price
of
the
underlying
foreign
securities,
and
their
value
may
change
materially
at
times
when
the
U.S.
markets
are
not
open
for
trading.
Investments
in
unsponsored
depositary
receipts
may
be
subject
to
additional
risks.
25
Warrants
Risk.
Warrants
can
provide
a
greater
potential
for
profit
or
loss
than
an
equivalent
investment
in
the
underlying
security.
Prices
of
warrants
do
not
necessarily
move,
however,
in
tandem
with
prices
of
the
underlying
securities,
particularly
for
shorter
periods
of
time,
and,
therefore,
may
be
considered
speculative
investments.
If
a
warrant
held
by
the
Company
were
not
exercised
by
the
date
of
its
expiration,
the
Company
would
incur
a
loss
in
the
amount
of
the
cost
of
the
warrant.
Market
Discount
from
Net
Asset
Value.
Shares
of
closed-end
investment
companies
such
as
the
Company
frequently
trade
at
a
discount
from
their
net
asset
value.
The
Company
cannot
predict
whether
its
common
shares
will
trade
at,
below
or
above
net
asset
value. 
This
characteristic
is
a
risk
separate
and
distinct
from
the
risk
that
the
Company’s
net
asset
value
could
decrease
as
a
result
of
investment
activities.
Valuation
Risk.
The
Company
may
not
be
able
to
sell
an
investment
at
the
price
at
which
the
Company
has
valued
the
investment.
Such
differences
could
be
significant,
particularly
for
illiquid
securities
and
securities
that
trade
in
relatively
thin
markets
and/or
markets
that
experience
extreme
volatility.
If
market
or
other
conditions
make
it
difficult
to
value
some
investments,
SEC
rules
and
applicable
accounting
protocols
may
require
the
Company
to
value
these
investments
using
more
subjective
methods,
known
as
fair
value
methodologies.
Using
fair
value
methodologies
to
price
investments
may
result
in
a
value
that
is
different
from
an
investment’s
most
recent
price
and
from
the
prices
used
by
other
funds
to
calculate
their
NAVs.
The
Company’s
ability
to
value
its
investments
in
an
accurate
and
timely
manner
may
be
impacted
by
technological
issues
and/or
errors
by
third
party
service
providers,
such
as
pricing
services
or
accounting
agents.
Market
Events
Risk.
Geopolitical
events,
including
pandemics
(such
as
COVID-19),
may
destabilize
various
countries’
economies
and
markets,
which
may
experience
increased
volatility
and
reduced
liquidity.
Policy
changes
by
the
Federal
Reserve
and/or
other
government
actors
could
similarly
cause
increased
volatility
in
financial
markets.
Trade
barriers
and
other
protectionist
trade
policies
(including
those
in
the
U.S.)
may
also
result
in
market
turbulence.
Market
volatility
and
reductions
in
market
liquidity
may
negatively
affect
issuers
worldwide,
including
issuers
in
which
the
Company
invests.
Under
such
circumstances,
the
Company
may
have
difficulty
liquidating
portfolio
holdings,
particularly
at
favorable
prices.
Also,
the
Company
may
be
required
to
transact
in
contemporaneous
markets,
even
if
they
are
volatile
and/or
illiquid,
which
may
negatively
impact
the
Company’s
net
asset
value.
The
global
outbreak
of
COVID-19
virus
has
caused
negative
effects
on
many
companies,
sectors,
countries,
regions,
and
financial
markets
in
general,
and
uncertainty
exists
as
to
its
long-term
implications.
The
effects
of
the
pandemic
may
adversely
impact
the
Company’s
assets
and
performance.
The
financial
statements
do
not
include
any
adjustments
that
might
result
from
the
outcome
of
this
uncertainty.
26
Board
of
Directors
and
Officers
of
ASA
Gold
and
Precious
Metals
Limited
(Unaudited)
Board
of
directors
and
officers
(Unaudited)
Directors
are
elected
at
each
annual
general
meeting
of
shareholders
to
serve
until
the
next
annual
general
meeting.
The
address
of
each
director
and
officer
is
c/o
ASA
Gold
and
Precious
Metals
Limited,
Three
Canal
Plaza,
Suite
600,
Portland,
ME
04101.
Independent
Directors
Other
Officers
Mary
Joan
Hoene
(72)
Position
held
with
the
Company:
Chair
(non-executive)
since
January
2019.
Deputy
Chair
(non-executive)
2016
to
2018.
Director
since
2014.
Principal
occupations
during
past
5
years:
Counsel,
Carter
Ledyard
&
Milburn
LLP
2010
to
2021.
Other
Directorships
held
by
Director:
None.
Bruce
Hansen
(64)
Position
held
with
the
Company:
Director
since
2014.
Principal
occupations
during
past
5
years:
Chief
Executive
Officer,
General
Moly,
Inc.
2007
to
2020.
Other
Directorships
held
by
Director:
Director,
Energy
Fuels
Inc.
since
2006;
Director,
General
Moly
Inc.
2007
to
2020;
Director
and
past
Chairman
(2011),
Nevada
Mining
Association
2010
to
2019;
Director,
New
Moly
LLC
since
2021.
Anthony
Artabane
(67)
Position
held
with
the
Company:
Director
since
2019.
Principal
occupations
during
past
5
years:
Managing
Member,
Anthony
Artabane
CPA,
PLLC
since
2014.
Other
Directorships
held
by
Director:
None.
William
Donovan
(62)
Position
held
with
the
Company:
Director
since
2020.
Principal
occupations
during
past
5
years:
President,
United
States
Steel
and
Carnegie
Pension
Fund
2011
to
2017.
Other
Directorships
held
by
Director:
None.
Axel
Merk
(52)
Position
held
with
the
Company:
Chief
Operating
Officer
since
March
2019.
Principal
occupations
during
past
5
years:
Founder,
President
and
Chief
Investment
Officer,
Merk
Investments
since
1994.
Karen
Shaw
(49)
Position
held
with
the
Company:
Chief
Financial
Officer
since
March
2019.
Principal
occupations
during
past
5
years:
Senior
Vice
President,
Apex
Fund
Services
since
2019;
Senior
Vice
President,
Atlantic
Fund
Services
2008
to
2019.
Peter
Maletis
(51)
Position
held
with
the
Company:
President
since
March
2019.
Principal
occupations
during
past
5
years:
Vice
President,
Merk
Investments
since
March
2019;
Research
Analyst,
Franklin
Templeton
Investments
2010
to
2019.
Jack
Huntington
(51)
Position
held
with
the
Company:
Chief
Compliance
Officer
since
September
2015.
Principal
occupations
during
past
5
years:
Fund
Chief
Compliance
Officer,
Foreside
Fund
Officer
Services,
LLC
since
2015;
Senior
Vice
President
and
Counsel,
Citi
Fund
Services
2008
to
2015.
Zachary
Tackett
(33)
Position
held
with
the
Company:
Corporate
Secretary
since
November
2019.
Principal
occupations
during
past
5
years:
Senior
Counsel,
Apex
Fund
Services
since
2019;
Counsel,
Atlantic
Fund
Services
2014
to
2019.
Other
Information
Shareholder
Services
ASA
Gold
and
Precious
Metals
Limited
Three
Canal
Plaza,
Suite
600
Portland,
ME,
U.S.A.
04101
(800)
432-3378
Registered
Office
Canon’s
Court
22
Victoria
Street
Hamilton
HM
12,
Bermuda
Investment
Adviser
Merk
Investments
LLC
Menlo
Park,
CA,
U.S.A.
Independent
Registered
Public
Accounting
Firm
Tait,
Weller
&
Baker
LLP,
Philadelphia,
PA,
U.S.A.
Counsel
Appleby,
Hamilton,
Bermuda
K&L
Gates
LLP,
Washington,
DC,
U.S.A.
Custodian
JPMorgan
Chase
Bank,
N.A.
New
York,
NY,
U.S.A.
Fund
Administrator
Apex
Fund
Services
Portland,
ME,
U.S.A.
Transfer
Agent
Computershare
Trust
Company,
N.A.
P.O.
Box
505000
Louisville,
KY,
U.S.A.
40233-5000
(800)
317-4445
Website:
www.asaltd.com
The
Semi-annual
and
Annual
Reports
of
the
Company
and
the
latest
valuation
of
net
assets
per
share
may
be
viewed
on
the
Company’s
website
or
may
be
requested
from
the
Executive
Office
(800-432-3378).
Shareholders
are
reminded
to
notify
Computershare
of
any
change
of
address.
 
ITEM 2. CODE OF ETHICS.
 
(a)
             
The registrant has adopted a code of ethics that applies to its principal executive officer and principal financial officer.
(b)
            
Not applicable.
(c)
             
During the period covered by this report, there was no amendment to the code of ethics referred to in this paragraph (a) of this Item that apply to a covered person and relate to any element of such code set forth in paragraph (b) of this Item 2.
(d)
            
During the period covered by this report, there were no waivers to the provisions of the code of ethics referred to in paragraph (a) of this Item.
(e)
             
Not applicable.
(f)
              
A copy of the registrant’s code of ethics is filed herewith.
 
ITEM 3. AUDIT COMMITTEE FINANCIAL EXPERT.
 
The registrant’s board of directors determined that Bruce Hansen, Chairman of the registrant’s Audit and Ethics Committee, is an “audit committee financial expert” as defined in the instructions to Item 3 of Form N-CSR. Mr. Hansen is “independent” as defined in Item 3 of Form N-CSR.
 
ITEM 4. PRINCIPAL ACCOUNTANT FEES AND SERVICES.
 
(a)
          
Audit Fees. The aggregate fees billed for professional services rendered by the independent auditors for the audit of the registrant’s annual financial statements and review of the semi-annual financial statements and services rendered in connection with statutory or regulatory filings for 2021 and 2020 were $30,000 and $30,000, respectively.
(b)
         
Audit-Related Fees – There were no fees billed for assurance and related services rendered by the independent auditors that were reasonably related to the performance of the audit or review of the registrant’s financial statements for 2021 and 2020.
(c)
          
Tax Fees – The aggregate fees billed for professional services rendered by the independent auditors in connection with tax compliance, tax advice and tax planning for 2021 and 2020 were $5,000 and $5,000, respectively. The figures for 2021 and 2020 include fees billed for U.S. tax advisory services.
(d)
         
All Other Fees – There were no non-audit fees not disclosed above that were billed for products and services provided by the independent auditors for 2021 and 2020.
(e)(1)  The Audit and Ethics Committee (“Committee”) of the registrant has the sole authority to pre-approve all audit and non-audit services to be provided by the independent auditors, subject to the de minimis exceptions for non-audit services described in Section 10A(i)(1)B of the Securities Exchange Act of 1934 (“Exchange Act”) which are approved by the Committee prior to the completion of the audit. Any individual project that does not exceed $25,000 may be pre-approved by the Chairman of the Committee. Any such pre-approval by the Chairman of the Committee must be presented to the full Committee at its next scheduled meeting. Any proposed services exceeding that cost level requires specific pre-approval by the Committee. Pre-approval of audit and non-audit services shall not be required if the engagement to render the services is entered into pursuant to pre-approved policies and procedures established by the Committee, provided the Committee is informed of each such service. The Committee has not established such policies and procedures.
(e)(2)  None of the services described in paragraphs (b) – (d) above were approved by the Audit and Ethics Committee pursuant to paragraph (c)(7)(i)(C) of Rule 2-01 of Regulation S-X.
(f)
           
Not applicable.
(g)
         
The aggregate fees billed by the independent auditors for non-audit services rendered to the registrant for 2021 and 2020 were $5,000 and $5,000, respectively.
(h)
         
Not applicable.
 

 
ITEM 5. AUDIT COMMITTEE OF LISTED REGISTRANTS.
 
(a)
             
The registrant has a standing audit committee established in accordance with Section 3(a)(58)(A) of the Exchange Act. The members of the audit committee are: Messrs. Bruce Hansen (Chair), Anthony Artabane, William Donovan and Ms. Mary Joan Hoene, which comprise the entire board of directors.
(b)
            
Not applicable.
 
ITEM 6. INVESTMENTS.
 
(a)
                
Included as part of the report to shareholders under Item 1.
 
(b)
               
Not applicable.
 
ITEM 7. DISCLOSURE OF PROXY VOTING POLICIES AND PROCEDURES FOR CLOSED-END
MANAGEMENT INVESTMENT COMPANIES.
 
ASA Gold and Precious Metals Limited
Proxy Voting Policies and Procedures
 
The following is a statement of the proxy voting policies and procedures of ASA Gold and Precious Metals Limited (“ASA”). 
 
Proxy Administration
 
ASA’s portfolio is primarily comprised of holdings in precious metals companies, and thus proxy voting will be done on proposals made by these issuing companies (“portfolio company” or “portfolio companies”).
 
Authority and responsibility to vote proxies with respect to ASA’s portfolio securities has been delegated to Merk Investments LLC (the “Adviser”). In evaluating proxy proposals, the Adviser may consider information from various sources, including the Board of Directors (“Board”) of ASA presenting a proposal, as well as independent sources.  The ultimate decision rests with the Adviser, who is accountable to the Board.
 
The Adviser understands its proxy voting responsibilities and that proxy voting decisions may affect the long-term interests of ASA’s shareholders.   The Adviser attempts to process every proxy vote it receives on behalf of ASA.  However, voting proxies for shares of certain non-U.S. companies may involve significantly greater effort and cost than voting proxies for shares of U.S. companies.   There may be situations where the Adviser  may not or cannot vote a proxy.  For example, the Adviser may receive proxy material too late to act upon or the cost of voting may outweigh the benefit of voting.  In addition, the Adviser may not receive proxy materials when it holds depository receipts, (“ADRs”) as opposed to the underlying securities.  Certain issuers do not instruct the holding banks to solicit proxies from depository receipt holders.
 
General Principles
 
For the purposes of ASA, a “portfolio company” is defined as a company in which ASA holds securities or assets.
 
In voting proxies, the Adviser  will act solely in the best economic interests of ASA’s shareholders with the goal of maximizing the value of ASA’s portfolio.  These policies and procedures are designed to promote accountability of a portfolio company’s management and board to its shareholders and to align the interests of those portfolio companies and their management with those of shareholders.  These policies and procedures recognize that a portfolio company’s managers are entrusted with the day-to-day operations of the company, as well as longer-term strategic planning, subject to the oversight of that company’s board.
 
ASA believes that the quality and depth of a portfolio company’s management and its board is an important consideration in determining the desirability of an investment.  Accordingly, the recommendations of the portfolio company’s board on many issues are given substantial weight in determining how to vote a proxy.  However, each issue is considered on its own merits, and the position of the portfolio company’s board will not be supported whenever it is determined not to be in the best interests of ASA and its shareholders.
 
Specific Policies
 
A.
                 
Routine Matters
 
1.
      
Election of Directors.  In general, the Adviser will vote in favor of the board’s director nominees if they are running unopposed.   ASA believes that the board is in the best position to evaluate the qualifications of its directors and the needs of a particular board.  Nevertheless, the Adviser will vote against, or withhold its vote for, any nominee whom the Adviser considers  is not qualified or appears to lacks sufficient independence.  When the board’s nominees are opposed in a proxy contest, the Adviser will evaluate which nominee’s publicly-announced management policies and goals are most likely to maximize shareholder value, as well as the past performance of the incumbent.
 
2.
      
Ratification of Selection of Auditors.  In general, the Adviser will rely on the judgment of the board in selecting the independent auditors.  Nevertheless, the Adviser will examine the recommendation of the board in appropriate cases (e.g., where there has been a change in auditors based upon a disagreement on accounting matters).
 
3.
      
Stock Option and Other Equity Based Compensation Plan Proposals.   The Adviser will generally approve the board’s recommendations with respect to the adoption or amendment of stock option plans and other equity based compensation plans, provided that the total number of shares reserved under all of a company’s plans is reasonable and not excessively dilutive.
 
B.
                 
Acquisitions, Mergers, Reincorporations, Reorganizations and Other Transactions
 
Because voting on transactions such as acquisitions, mergers, reincorporations and reorganizations involve considerations unique to each transaction, ASA does not have a general policy in regard to voting on those transactions.   The Adviser will vote on a case-by-case basis on each transaction.
 
C.
                 
Changes in Capital Structure
 
The Adviser evaluates proposed capital actions on a case-by-case basis and will generally defer to the business analysis of the portfolio company’s board in support of such actions.  In cases where proposed capital actions support proxy defenses or act to reduce or limit shareholder rights, particular consideration will be given to all the effects of the action, and the Adviser’s vote will be made in a manner consistent with the objective of maximizing long-term shareholder value for ASA.
 
D.
                 
Anti-Takeover Proposals
 
In general, the Adviser will vote against any proposal which the Adviser believes would materially contribute to preventing a potential acquisition or takeover of the portfolio company, including proposals to:
 
·
        
Stagger the board;
·
        
Introduce cumulative voting;
·
        
Introduce unequal voting rights;
·
        
Create supermajority voting;
·
        
Establish preemptive rights.
 
In general, the Adviser will vote in favor of any proposals to reverse the above.
 
E.
                 
Shareholder Proposals Involving Social, Moral or Ethical Matters
 
In general, the Adviser will vote in accordance with the recommendation of the portfolio company’s board on issues that primarily involve social, moral or ethical matters, although exceptions may be made in certain instances where the Adviser believes a proposal has substantial economic implications.
 
F.
                  
Conflict of Interest
 
Any actual or potential conflicts of interest between the Adviser and the Company’s shareholders arising from the proxy voting process will be addressed by the Adviser and the Adviser’s application of its proxy voting procedures pursuant to the delegation of proxy voting responsibilities to the Adviser. In the event that the Adviser notifies the CCO that a conflict of interest cannot be resolved under the Adviser’s Proxy Voting Procedures, the CCO is responsible for notifying the Chair of the Board of the irreconcilable conflict of interest and assisting the Chair with any actions she or he determines are necessary.
 
A “conflict of interest” includes, for example, any circumstance when the Company, the Adviser or one or more of their affiliates (including officers, directors and employees) knowingly does business with, receives compensation from, or sits on the board of, a particular issuer or closely affiliated entity, and therefore, may appear to have a conflict of interest between its own interests and the interests of Company shareholders in how proxies of that issuer are voted. Situations where the issuer seeking the proxy vote is also a client of the Adviser are deemed to be potential conflicts of interest. Potential conflicts of interest may also arise in connection with consent solicitations relating to debt securities where the issuer of debt is also a client of the Adviser.
 
In cases of a conflict of interest, a record shall be maintained confirming that the Adviser’s vote was made solely in the interests of ASA and without regard to any other consideration.
 
G.      Recordkeeping
 
The Adviser uses ProxyEdge, a third party automated proxy voting service.  Where appropriate, rationales for “No” votes cast by the Adviser will be supported by footnoted documentation on ProxyEdge.  According to the Proxy Edge website, this service is a “suite of electronic voting services that help simplify the management of institutional proxies.  The system manages the process of meeting notifications, voting, tracking, mailing, reporting, record maintenance and even vote disclosure rules enacted by the SEC.”  
 
Revised and Re-Approved December 12, 2019
 
Proxy Voting
The following is a statement of the proxy voting policies and procedures of registrant’s investment adviser, Merk Investments LLC (“Merk”).
Introduction
Merk exercises its voting authority with a goal of maintaining or enhancing shareholder value of the companies in which it has invested Advisory Client assets. Unless an Advisory Client specifically reserves the right, in writing, to vote its own proxies, Merk will vote proxies in accordance with its proxy voting policy.  Merk
is
committed
to
minimizing
conflicts
of
interest
when
voting
proxies on
behalf
of
Advisory
Clients
and strives
to
ensure
that
proxies
are
voted
in
the
best
interests of Advisory Clients, including investors in the Private Funds. Merk has
adopted
the
following:
 
·
     
For
routine
matters,
as
the
quality
and
depth
of
management
is
a
primary
factor considered
when
investing
in
an
issuer,
the
recommendation
of
the
issuer's
management on
any
issue
will
be
given
substantial
weight.
The
position
of
the
issuer's
management will
not
be
supported
in
any
situation
where
Merk
assesses
that
it
is
not
in
the
best interests
of
Clients and investors.
·
     
For
non-routine
matters,
such
proposals
should
be
examined
on
a
case-by-case
basis.
·
     
Merk
may
abstain
from
voting
a
proxy
if
such
vote
cannot
be cast
with
commercially
reasonable
efforts
or
if
Merk
deems
it
to
be
in the
best
interest
of
Advisory Clients and investors to
abstain
from
voting
a
proxy.
·
     
Merk may choose to abstain from voting for routine matters when it agrees with the recommendation of the issuer's management.
Responsibility
The CCO
has
the
responsibility
for
monitoring
compliance with
our proxy
voting
policy,
practices,
disclosures
and
record
keeping,
including
outlining
our
voting guidelines
in
our
procedures.
Procedure
As a general rule, conflicts of interest will be resolved by Merk
voting in accordance with its proxy voting policy when: Merk
 manages the account of a corporation or a pension fund sponsored by a corporation in which Advisory Clients of Merk
also own stock; a Supervised Person or a member of his/her immediate family is on the Board of Directors or a member of senior management of the company that is the issuer of securities held in an Advisory Client’s account; or Merk
has a material relationship with a corporation whose securities are the subject of the proxy.
 
If Merk determines that it has a conflict of interest with respect to voting proxies on behalf of the Merk Mutual Funds, the CIO or CCO shall contact the Chairman of the Board of Registered Funds to seek their voting recommendation.  Merk shall vote the proposal according the determination of the Board and maintain records relating to this process.
 
Advisory Clients that wish to obtain information on how specific proxies were voted, or a copy of Merk’s   proxy voting policy, may contact the CCO.
Recordkeeping
Merk shall
retain
the
following
proxy
records
in
accordance
with
the
SEC’s five-year
retention
requirement:
·
     
These
policies
and
procedures
and
any
amendments;
·
     
Each
proxy
statement
that
the Firm
receives;
·
     
A
record
of
each
vote
that
the Firm
casts;
·
     
Any
documents
prepared
by
the
Firm
that
were
material
to
making
a
decision
how
to vote
proxies,
or
that
memorializes
the
basis
of
that
decision.
 
ITEM 8.  PORTFOLIO MANAGERS OF CLOSED-END MANAGEMENT INVESTMENT COMPANIES.
 
Unless otherwise indicated, the information set forth below is as of November 30, 2021.
 
(a)(1) As of the date of this filing, on form N-CSR, Peter J. Maletis, President of the registrant since March 2019, is responsible for the day-to-day management of the registrant’s portfolio (the “Portfolio Manager”). Mr. Maletis joined the Merk Investments as Vice President in March 2019. He served as Research Analyst at Franklin Templeton Investments from 2010 to 2019.
 
(a)(2) Other Accounts Managed by the Portfolio Manager. The chart below shows the number of other accounts managed by the Portfolio Manager as of November 30, 2021.
 
PORTFOLIO MANAGER
REGISTERED INVESTMENT COMPANIES ($)
OTHER POOLED INVESTMENT VEHICLES ($)
OTHER ACCOUNTS ($)
Peter J. Maletis
  
None
None
  
None
 
(a)(3) Compensation of the Portfolio Manager.  The compensation of the Portfolio Manager is comprised of a fixed annual salary and a variable compensation based on the assets of the Fund. The Portfolio Manager may be eligible to receive additional compensation based on certain factors, including but not limited to, the economic performance of the Adviser. Any amounts earned by the Portfolio Manager are payable by the Adviser and not by the Fund.
 
(a)(4) Beneficial Ownership by Portfolio Manager.  As of November 30, 2021, the dollar range of shares of the Registrant owned by the Portfolio manager was $10,001 - $50,000.
 
(b)       Not applicable.
 
ITEM 9. PURCHASES OF EQUITY SECURITIES BY CLOSED-END MANAGEMENT INVESTMENT COMPANY AND AFFILIATED PURCHASERS.
 
During the period covered by this report, there were no purchases made by or on behalf of the registrant or any “affiliated purchaser,” as defined in Rule 10b-18(a)(3) under Securities Exchange Act of 1934 (the “Exchange Act”), of any common shares of the registrant.
 
ITEM 10. SUBMISSION OF MATTERS TO A VOTE OF SECURITY HOLDERS
 
There have been no material changes to the procedures by which shareholders may recommend nominees to the registrant’s board of directors since the registrant provided disclosure in response to Item 22(b)(15) of Schedule 14A in its proxy statement dated February 21, 2019.
 
ITEM 11. CONTROLS AND PROCEDURES
 
(a)
          
The Principal Executive Officer and the Principal Financial Officer, in their capacities as principal executive officer and principal financial officer of the registrant, have concluded that the registrant’s disclosure controls and procedures (as defined in Rule 30a-3(c) under the Investment Company Act of 1940 (the “1940 Act”)) are effective, based on their evaluation of these controls and procedures as of a date within 90 days prior to the filing date of this report.
 
(b)       There were no changes in the registrant’s internal control over financial reporting (as defined in Rule 30a-3(d) under the 1940 Act) that occurred during the second fiscal quarter of the period covered by this report that have materially affected, or are reasonably likely to materially affect, the registrant’s internal control over financial reporting.
 
ITEM 12. DISCLOSURE OF SECURITIES LENDING ACTIVITIES FOR CLOSED-END MANAGEMENT INVESTMENT COMPANIES
 
The Registrant did not participate in securities lending activities during the year ended November 30, 2021.
 
ITEM 13. EXHIBITS.
 
 
 
(a)(3)  Not applicable.
 
(a)(4)  Not applicable.
 

 

SIGNATURES

 
Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, the Registrant has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized.
 
Registrant              ASA Gold and Precious Metals Limited
 
By          /s/ Axel Merk                                                                       
               Axel Merk, Principal Executive Officer
              
Date       1/25/2022                                                                             
 
 
Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, this report has been signed below by the following persons on behalf of the Registrant and in the capacities and on the dates indicated.
 
By          /s/ Axel Merk                                                                       
               Axel Merk, Principal Executive Officer
              
Date       1/25/2022                                                                             
 
By          /s/ Karen Shaw                                                                    
               Karen Shaw, Principal Financial Officer
              
Date       1/25/2022                                                                             
 
 
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