Tshipi é Ntle Manganese Mining Proprietary Limited is committed to a culture of ethical behaviour and integrity in the conduct of its business as set out in the principles of King IV (Report on Corporate Governance in South Africa). The Company is committed to high moral, ethical and legal standards in dealing with all of its stakeholders. All the shareholders, directors, employees, agents, advisors and contractors of the Company are required to maintain high ethical standards to ensure that the Company’s business is conducted legally, honestly and in the best interests of the Company and its stakeholders.

Tshipi is committed to good governance and compliance with legislative requirements at all levels of the business and in all its interactions with stakeholders. This Code is based on the ethical values of responsibility, accountability, fairness and transparency that underpin good corporate governance. The Company fully embraces the inclusive stakeholder approach. The ethical standards set out in this Code are integrated into Tshipi’s business strategies and operations.

The Code is based on principles rather than rules. The complexity of business makes it impractical to formulate a code of ethics that provides detailed rules for every conceivable situation where ethical considerations may be relevant. The Company expects from all Applicable Persons to apply the ethical principles described in this Code in a way that consistently results in ethical business conduct.

The Company is dedicated to carrying out its operations in a socially responsible manner. The Company considers ethical and environmental factors to be integral to the long term sustainability of its business. It furthermore recognises its responsibility to act as a good corporate citizen and performs its obligations towards its employees, shareholders, customers, suppliers, competitors and the community within which it operates, in good faith. The Company believes that its reputation, together with the trust and confidence of those with whom it deals, is one of its most valuable assets. In order to keep this reputation and trust, the Company demands and maintains the highest ethical standards in carrying out its business activities.

The Company is further committed to a Social Contract with its employees and contractors. This Social Contract fosters the values and culture of respect for human dignity, ethical conduct in all business dealings, trust and sustainability.

The Company has a whistle blowing policy and programme intended to reinforce and implement the Company’s commitment to the highest standards of professional integrity, ethical behaviour, transparency and fair dealing in the conduct of its business.

The Chief Executive Officer on behalf of the Company’s management and the Chairman on behalf of the Board of directors have endorsed this Code of Ethics. It is expected that all stakeholders and Applicable Persons who are involved in the running of the business and/or who have dealings with the Company including, but not limited to, the leadership and management of the Company, employees, suppliers, and contractors will abide by and adhere to this Code of Ethics.