NI 51-101 is applicable to all reporting issuers engaged in oil and gas activities, whether directly or indirectly (section 1.3 of NI 51-101) involved. A reporting issuer could still be engaged in oil and gas activities even if it did not have assigned reserves or production. Oil and gas activities must be reported if they are material (see section 1.4 of NI 51-101) to the company’s business operations.