Code of Ethics

This code of ethics outlines the moral and legal requirements for FIRST QUANTUM CAPITAL Corporation's directors, officers, and staff. This Code is meant to prevent wrongdoing and encourage honest dealing in all Company activity.

Compliance with Laws, Rules and Regulations

FIRST QUANTUM CAPITAL and its affiliates manages its operations in full compliance with international and local laws and regulations, global voluntary codes and standards, our own core policies and contractual obligations with third parties, to prevent possible violations and to take necessary measures.

Our Policy includes inclusive and regulatory principles which encompasses first and foremost our employees as well as our business partners in our entire value chain and covers all managers, staff and applies to all activities at governance, management and operational levels. First Quantum Capital Legal and Compliance Policy forms the foundations that enable the Company and its affiliates to implement its corporate business ethics philosophy as the integral part of the First Quantum Capital Control Framework.

Carried out in line with the legal regulations and the Code of Ethics, which we are committed to comply with at all stages of all our activities, this policy includes the following basic principles:

1. With a high level of ethical understanding, we comply with all legal regulations and manage compliance processes as part of risk management by taking all necessary measures.

2. As a significant representative of the global community in the business world, we support all the principles contained in the Universal Declaration of Human Rights and declare that we are against discrimination at every stage of our activities.

3. We require a respectful human rights approach from every business partner, including suppliers.

4. We give special importance to establishing dialogue platforms regarding human rights while operating our businesses and managing its processes and take precautions to protect the rights of local communities.

5. We undertake to comply with fair trade principles included in the United Nations Sustainable Development Goals in all our activities.

6. We comply with all legal regulations regarding the protection of the ecological environment in the regions where we operate, and we make maximum efforts to reduce our environmental impact.

7. We protect the corporate, personal and asset information we have gathered through our activities in accordance with the legal regulations, and we take all measures regarding information security.

8. While taking the necessary precautions regarding the health and safety of our employees, we provide the best working conditions for them, and we manage and control the processes necessary to prevent unethical behavior that may put our company's reputation and assets at risk.

9. In addition to being a role model for compliance, all of the managers of our company declare that they assume full responsibility to ensure that the First Quantum Capital Control Framework is fully understood both inside and outside the company.

First Quantum Capital also works with the legal and business teams to facilitate ongoing education and training to ensure that our managers and their teams are aware of their specific compliance responsibilities. Similarly, managers are responsible for developing and enhancing procedures and processes within the framework provided, to ensure all business activities take account of any relevant legal obligations.

We comply with professional standards and applicable laws and regulations and avoid any action including but not limited to the following, that may discredit our firms or our professions;

Reporting and Compliance Procedures.

Every employee, officer, and director have the responsibility to ask questions, seek guidance, report suspected violations and express concerns regarding compliance with this Code. Any employee, officer or director who knows or believes that any other employee or representative of the Company has engaged or is engaging in Company-related conduct that violates applicable law or this Code should report such information to his or her supervisor or to the General Counsel. Such reports should be made without any fear of retaliation. The Company will not discipline, discriminate against or retaliate against any employee who reports such conduct unless it is found that the report was made with knowledge that it was false, or who cooperates in any investigation or inquiry regarding such conduct.

Conflicts of Interest

Employees, officers, and directors must act in the best interests of the Company. You must refrain from engaging in any activity or having a personal interest that presents a " conflict of interest." It is your responsibility to disclose any transaction or relationship that reasonably could be expected to give rise to a conflict of interest.

Confidentiality

Employees, officers and directors must maintain the confidentiality of confidential information entrusted to them in their capacity with FIRST QUANTUM CAPITAL Corporation. Unauthorized disclosure of any confidential information is prohibited. Additionally, employees should take appropriate precautions to insure that confidential or sensitive business information, whether it is proprietary to the Company or another company, is not communicated within the Company except to employees who have a need to know such information to perform their responsibilities.

Honest and Ethical Conduct and Fair Dealing

Employees, officers, and directors should deal honestly, ethically and fairly with the FIRST QUANTUM CAPITAL Corporation's suppliers, customers, competitors, and employees. Statements regarding the Company's products and services must not be untrue, misleading, deceptive or fraudulent. You must not take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts or any other unfair dealing practice.

Protection and Proper Use of Corporate Opportunities

Employees, officers, and directors must advance the Company's legitimate interests when the opportunity to do so arises. You must not take for yourself personal opportunities that are discovered through your position with the Company or the use of property or information of the Company.

Accuracy of Books and Records and Public Reports

Employees, officers, and directors must honestly and accurately report all business transactions. You are responsible for the accuracy of your records and reports. Accurate information is essential to the Company's ability to meet legal and regulatory obligations.