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Item 16B. Code of Ethics

We adopted a Code of Business Conduct (the “Code of Conduct”) in connection with our IPO, which covers a broad range of matters including the handling of conflicts of interest, compliance issues and other corporate policies. The Code of Conduct applies to all of our executive officers, board members and employees.

Our Code of Conduct may be found on our website at www.guardianmetalresources.com (the contents of our website are not incorporated by reference into this Annual Report on Form 20-F).

No amendments to, and no waivers (including implicit waivers) from, any provision of the Code of Conduct were made or granted with respect to any of our directors or executive officers during the fiscal year ended June 30, 2026.

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