Almonty Industries Inc.

Ensuring Compliance with this Code

The Corporation expects each of its Employees to read and become familiar with the requirements and standards described in this Code. As part of its efforts to ensure compliance with this Code, the Corporation requires that certain Employees complete an annual signoff certifying compliance therewith. Employees whose positions may include involvement with foreign operations may also be asked to complete more frequent or comprehensive signoffs to confirm their obligations to comply with anti-bribery legislation as described under “International Business” above.

The Corporation fully expects that Employees will report on a timely basis any observed breaches of this Code to the Chief Executive Officer, or through the Corporation’s Whistleblower Policy.

An Employee, contractor or consultant who violates this Code may face disciplinary action up to and including termination. Violation of this Code may also cause violation of certain laws and regulations. If it is discovered that laws or regulations have been violated, this matter may be referred to the appropriate regulatory authorities.

Questions with respect to this Code may be referred to the Corporation’s Chief Executive Officer or Chief Financial Officer.