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ITEM 16B. - CODE OF ETHICS

On November 8, 2016 the registrant’s Board of Directors approved in principle, and the Company formally adopted on March 7, 2017, a revised code of business conduct, ethics and anti-bribery policy that applies to the registrant’s directors, CEO, CFO, principal accounting officer or controller, or persons performing similar functions, and all other employees and contractors. The code was revised in June 2018, November 2020, November 2024 and August 2025 to remove references to the Toronto Stock Exchange (following the delisting of the Company’s shares from there in 2020), include references to new laws and policies, provide clarifications as to conflicts of interest and gift and hospitality reporting and updating contact details for the whistleblowing service. The most recent updated version was adopted on August 5, 2025.

The text of this code is available on the Company’s website: (www.caledoniamining.com/index.php/aboutus/corporate-governance).

The Company has not granted any waiver from the Code of Ethics to the CEO, CFO, principal accounting officer or controller, or persons performing similar functions during the fiscal year ended December 31, 2025.

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