Almonty Industries Inc.

CODE OF BUSINESS CONDUCT

Almonty Industries Inc. and its subsidiaries (collectively, the “Corporation”) are committed to the highest standards of legal and ethical business conduct and behaviour, including promotion of the following fundamental values:

All activities carried out by the Corporation and its directors, officers, employees and other representatives (collectively referred to herein as “Employees”) must be in compliance with all applicable laws and regulations. This obligation, however, is merely a starting point. It is equally important that all activities be conducted in an ethical manner. Ethical conduct means conduct that is honest, fair and free from deception and impropriety. Employees must, at all times, act in accordance with a high standard of ethical behaviour and with constant regard for the Corporation’s reputation. As discussed in this Code of Business Conduct (the “Code”), these requirements apply to dealings with the Corporation, fellow Employees, shareholders, suppliers, other businesses and the community at large.

Ultimately, each individual should test his or her own behaviour by asking: “Is there any reason why I would not want another person - the Corporation, a co-worker, a business associate, or the government - to be fully aware of my conduct and motives?” If this question causes any discomfort the individual should reconsider his or her conduct.