First Phosphate Corp

The Company has adopted a code of business conduct and ethics for directors, officers, employees and consultants (including the Company's principal executive officer, principal financial officer and principal accounting officer) (the "Code"). A copy of the Code is incorporated by reference into this Form 20-F as Exhibit 11.1. A copy of the Code may also be obtained free of charge from the Chief Financial Officer of the Company atbennett@firstphosphate.com and is also available on SEDAR+ atwww.sedarplus.ca, EDGAR atwww.sec.gov and the Company's website atwww.firstphosphate.com. Reports of violations should be made to their immediate supervisor and to the Company’s Chief Financial Officer, or the Audit Committee Chair.

No waiver from a provision of the Code was granted by the Company during the Company's most recently completed financial year. The Code was amended in July 2024 to include the Form 20-F requirements, and other technical, administrative and other non-substantive amendments.