TryHard Holdings Ltd

ITEM 16B. CODE OF ETHICS

We have a written code of business conduct and ethics that applies to our Directors, officers and employees, including our Chief Executive Officer, Chief Financial Officer, principal accounting officer or controller or persons performing similar functions. A current copy of this code is attached here as an exhibit to this Annual Report. We intend to disclose any amendments to the code of business conduct and ethics, and any waivers of the code of business conduct and ethics for our directors, executive officers and senior finance executives, on our website to the extent required by applicable U.S. federal securities laws and the corporate governance rules of the Nasdaq Capital Market.