SCHEDULE 13D 0001562639 XXXXXXXX LIVE Common Shares, no par value 03/01/2024 0001543418 89621C105 Trilogy Metals Inc.

Suite 901, 510 Burrard Street Vancouver A1 V6C 3A8

Kimberley Anderson (206) 903-8803 Dorsey & Whitney LLP 701 Fifth Avenue, Suite 6100 Seattle WA 98104 0001562639 N Tony Giardini PF OO Z4 8169131 0 8169131 0 8169131 5.0 IN THIS SCHEDULE 13D IS BEING FILED LATE DUE TO AN INADVERTENT ADMINISTRATIVE ERROR Common Shares, no par value Trilogy Metals Inc. Suite 901, 510 Burrard Street Vancouver A1 V6C 3A8 Tony Giardini ("Reporting Person") Trilogy Metals Inc. Suite 901, 510 Burrard Street Vancouver, British Columbia V6C 3A8 Canada The Reporting Person is the President and Chief Executive Officer and a director of Trilogy Metals Inc. (the "Issuer"). The Reporting Person has not, during the last five years, been convicted in a criminal proceeding (excluding traffic violations or similar misdemeanors). The Reporting Person has not, during the last five years, been a party to a civil proceeding of a judicial or administrative body of competent jurisdiction, and as a result of such proceeding was or is subject to a judgment, decree or final order enjoining future violations of, or prohibiting or mandating activities subject to, federal or state securities laws or finding any violation with respect to such laws. Canadian PF and OO The Reporting Person received from the Issuer compensatory awards from of restricted stock units and options in the ordinary course of business - see Schedule A As of March 1, 2024: 8,169,131 Shares consisting of 5,279,064 Common Shares plus 2,890,067 Common Shares underlying employee stock options held by the Reporting Person As of October 19, 2025: 11,532,060 Shares, consisting of 8,332,060 Common Shares plus 3,200,000 Common Shares underlying employee stock options held by the Reporting Person and exercisable within the next 60 days. See Exhibit 99.1 attached hereto See Exhibit 99.1 attached hereto Not Applicable Not Applicable None Exhibit 99.1 List of Transactions Tony Giardini /s/ Tony Giardini 10/24/2025