Titan America SA

Titan America has adopted a code of conduct (the “Code of Conduct”) applicable to all of Titan America directors, officers and employees, which is a “code of ethics” as defined in Item 16B of Form 20-F promulgated by the SEC. The Code of Conduct sets out Titan America’s fundamental values and standards of behavior that are expected from Titan America’s directors, officers and employees with respect to all aspects of Titan America’s business. The objective of the Code of Conduct is to provide guidelines for maintaining Titan America’s integrity, reputation and honesty with a goal of honoring others’ trust in us at all times.

The full text of the Code of Conduct is posted on our website at www.titanamerica.com. Under Item 16B of the SEC’s Form 20-F, if a waiver or amendment of the Code of Conduct applies to Titan America’s principal executive officer, principal financial officer, principal accounting officer or controller and relates to standards promoting any of the values described in Item 16B(b) of Form 20-F, we will disclose such waiver or amendment on our website in accordance with the requirements of Instruction 4 to such Item 16B.

Our board of directors is responsible for reviewing and evaluating the Code of Conduct periodically. Our board of directors will also monitor compliance with our Code of Conduct and is responsible for considering any waivers therefrom.