Americas Gold & Silver Corp

The Company has adopted the Code of Business Conduct and Ethics which applies to directors, officers and employees of, and consultants to, the Company. The Code of Business Conduct and Ethics is posted on the Company’s website at https://americas-gold.com/corporate/corporate-governance/. The Code of Business Conduct and Ethics meets the requirements for a “code of ethics” within the meaning of that term in General Instruction 16B of Form 20-F.

No amendments to the Code of Business Conduct and Ethics were made during the fiscal year ended December 31, 2023.

All waivers of the Code of Business Conduct and Ethics with respect to any of the employees, officers or directors covered by it will be promptly disclosed as required by applicable securities rules and regulations. During the fiscal year ended December 31, 2023, the Company did not waive or implicitly waive any provision of the Code of Business Conduct and Ethics with respect to any of the Company's principal executive officer, principal financial officer, principal accounting officer or controller, or persons performing similar functions.