Element 25

Code of Conduct for Directors and Executives

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Element 25: Global EV Grade Manganese

All directors and executives will act in accordance with the following:

Actively promote the highest standards of ethics and integrity in carrying out their duties for the Company.

Disclose any actual or perceived conflicts of interest of a direct or indirect nature of which they become aware and which they believe could compromise in any way the reputation or performance of the Company.

Respect confidentiality of all information of a confidential nature which is acquired in the course of the Company’s business and not disclose or make improper use of such confidential information to any person unless specific authorisation is given for disclosure or disclosure is legally mandated.

Deal with the Company’s contractors, suppliers, competitors and with each other with the highest level of honesty, fairness and integrity and to observe the rule and spirit of the legal and regulatory environment in which the Company operates.

Protect the assets of the Company to ensure availability for legitimate business purposes and ensure all corporate opportunities are enjoyed by the Company and that no property, information or position belonging to the Company or opportunity arising from these are used for personal gain or to compete with the Company.

Report any breach of this Code of Conduct for Directors and Executives to the Chair, who will treat reports made in good faith of such violations with respect and in confidence.

This Code of Conduct for Directors and Executives is in addition to the Code of Conduct which has been adopted by the Board of the Company.