Code of Business Conduct and Ethics

This Code of Business Conduct and Ethics (the "Code") is intended to document the principles of conduct and ethics to be followed by Silver Bow Mining Corp. (the "Company"), its employees, officers and directors (who are referred to collectively as "Employees" in this Code). Its purpose is to: promote honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships; promote avoidance of conflicts of interest, including disclosure to an appropriate person of any material transaction or relationship that reasonably could be expected to give rise to such a conflict; promote full, fair, accurate, timely and understandable disclosure in reports and documents that the Company files with, or submits to, the securities regulators and in other public communications made by the Company; promote compliance with applicable governmental laws, rules and regulations; promote the prompt internal reporting to an appropriate person of violations of this Code; promote accountability for adherence to this Code; provide guidance to Employees to help them recognize and deal with ethical issues; provide mechanisms to report unethical conduct; and help foster the Company's culture of honesty and accountability.

The Company requires all its Employees and consultants/contractors to be familiar with and adhere to this Code. This Code has been adopted pursuant to U.S. and Canadian securities laws and stock exchange rules, including Item 406 of Regulation S-K under the U.S. Securities Exchange Act of 1934, as amended, and Section 807 of the NYSE American LLC Company Guide.

Violations of this Code are grounds for disciplinary action up to and including immediate termination and possible legal prosecution. Employees are expected to promptly report violations of the Code and assist and co-operate with audits and investigations related to the Code and other policies of the Company.

This Code outlines a framework of guiding principles. As with any statement of policy, the exercise of judgment is required in determining the applicability of this Code to each individual situation.

It is the responsibility of every Company Employee to read and understand the Code. Individuals must comply with the Code in both letter and spirit. Ignorance of the Code will not excuse individuals from its requirements.

Never engage in behavior that harms the reputation of the Company.

This Code applies to all Employees of the Company and its subsidiaries. Employees are expected to comply with all aspects of this Code and to support others in doing so. Employees with executive or managerial responsibilities must ensure that the Code is communicated to and understood by Employees reporting to him or her, and are required to sign an annual acknowledgement of adherence to the Code.

In the event that an individual violates this Code, Company policies and procedures, or any of the laws that govern the Company's business, the Company will take immediate and appropriate action up to and including termination, claims for reimbursement of losses or damages and reference to criminal authorities.

The Code contains policy statements for key areas of business conduct. The Code addresses many of the issues of concern to the Company but cannot be exhaustive. Employees are encouraged to seek guidance from management or legal advice from Company counsel on issues that are not fully addressed in the Code. Employees who have questions about the application of the Code to specific situations should seek guidance from their supervisor, the CEO or the Audit Committee Chair.

A request for a waiver of any provision of the Code shall be in writing and shall be addressed to and reviewed by the Audit Committee. The Audit Committee's determination shall be made in a timely fashion, documented, and retained in accordance with applicable law. Any waiver of this Code for directors or executive officers must be approved by the Board of Directors and promptly disclosed as required by applicable securities laws and the rules of the stock exchanges on which the Company is listed.

Each Employee must at all times comply fully with applicable laws and regulations, and should avoid any situation that could be perceived as improper or unethical, or indicate a casual attitude towards compliance with the law.

No Employee shall commit or condone an illegal act or instruct another Employee to do so. No Employee shall create or condone the creation of a false record. No Employee shall destroy or condone the destruction of a record, except in accordance with Company policies.

Employees are expected to be sufficiently familiar with any legislation or regulation that applies to their duties and shall recognize potential liabilities, seeking advice where appropriate. In those circumstances where timely guidance or legal advice is not available, Employees should conduct themselves in a manner which would permit full public disclosure.

Employees of the Company shall avoid situations where their personal interest could, or could appear to, conflict with the interests of the Company. Employees shall perform the responsibilities of their positions on the basis of what is in the best interests of the Company and free from the influence of personal considerations and relationships.

Employees are required to disclose, in writing, all business, commercial or financial interests or activities where these might reasonably be regarded as creating an actual or potential conflict with their duties as Employees of the Company.

Employees shall not accept an appointment to a board of directors, standing committee or similar body of a public or private company or organization (other than an industry, professional, social, charitable, educational, religious or political organization) without prior approval of the CEO of the Company or the Board of Directors, as applicable.

In the event that any potential conflict of interest arises and the individual involved is an Employee of the Company, the individual involved must immediately notify their immediate supervisor and the Audit Committee. If such individual is a director of the Company, the Chairman of the Board of Directors or, in the absence of a Chair, all the members of the Board of Directors must be immediately notified.

The Company is committed to the highest level of honesty and integrity and therefore does not tolerate fraud or bribery. Fraud can include a wide range of activities, such as falsifying books, records or timesheets, embezzlement, skimming and misappropriating the Company's assets (including such things as proprietary information and corporate opportunities) for personal gain.

The Corruption of Foreign Public Officials Act (Canada) and Foreign Corrupt Practices Act of 1977 (U.S.) prohibit the bribing of government officials in order to obtain or retain business. Both laws prohibit paying indirectly what it is not permissible to pay directly; third-party intermediaries cannot be used to pay bribes.

There are serious criminal and civil consequences for fraud and bribery, including fines and imprisonment, and we consider fraud and the payment of bribes or other corrupt activity serious misconduct and grounds for dismissal.

Employees should endeavor to deal fairly with the Company's clients, service providers, suppliers, and Employees. No Employee should take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts or any unfair dealing practice.

The Company is a valuable customer for many suppliers of goods, services and facilities. People who want to do business, or to continue to do business, with the Company must understand that all purchases by the Company will be made exclusively on the basis of price, quality, service and suitability to the Company's needs.

No Employee shall make any form of payment, direct or indirect, to any public official as inducement to procuring or keeping business or having a law or regulation enacted, defeated, or violated.

When not prohibited by law, Employees are allowed to give to public officials gifts where the presentation and acceptance of gifts is an established custom and a normal business practice. All such gifts shall be of reasonable value and the presentation approved in advance by the Company's Chief Executive Officer ("CEO").

The Company may from time-to-time make donations to charities or non-governmental organizations. Such donations require prior Board approval if above $10,000. Employees must comply with applicable campaign finance laws regarding personal political activities and should not represent that personal political views are those of the Company.

The Company is committed to providing equal opportunity in all aspects of employment and to fostering an inclusive workplace. We prohibit discrimination based on legally protected characteristics and strive to make employment decisions based on qualifications and performance. Employees are expected to treat colleagues, customers, suppliers, and others with respect and dignity. Further guidance is provided in the Company's Diversity Policy.

The Company is committed to responsible mining practices that protect the environment, provide safe working conditions and respect the communities where we operate. The Company aims to: consider safety, environmental, and social factors in business decisions; promote workplace health and safety; use resources efficiently and manage waste responsibly; minimize environmental impact and conduct appropriate reclamation; and engage constructively with governments and communities.

The Company will support these commitments through appropriate management systems, employee training, and accountability measures. We expect employees, contractors, and business partners to conduct activities in alignment with these principles.

Agents or other non-employees cannot be used to circumvent the law. Employees will not retain agents or other representatives to engage in practices that run contrary to this Code.

The Company recognizes that a motivated and engaged workforce is essential to our success. The Company is committed to fostering open and honest communication, providing fair opportunities for professional development, and recognizing the impact our operations have on employees, their families, and communities. We expect all employees to contribute to a respectful workplace free from harassment.

While the Company does not prohibit the employment of relatives, it recognizes that personal relationships in the workplace can create potential conflicts of interest or perceptions of favoritism. Employees must disclose to Human Resources or their supervisor any relatives who work for the Company or who are being considered for employment. Relatives should not work in positions where one relative would directly supervise another, would be responsible for auditing or verifying another's work, or where the relationship would create a conflict of interest or the appearance of impropriety.

Directors must disclose any relatives employed by the Company as part of their annual disclosure of potential conflicts of interest.

The Company is committed to providing a workplace free from harassment and discrimination. Harassment, including sexual harassment, and discrimination in any form will not be tolerated. Employees who believe they have experienced or witnessed inappropriate conduct should report it through the appropriate channels as outlined in the Company's workplace policies.

The Company has a policy of "zero tolerance" regarding the misuse of prohibited substances, as mining operations involve safety-critical activities where impairment can lead to serious accidents, injuries, or fatalities. The Company maintains a substance testing program in accordance with Montana Code Ann. 39-2-207, including pre-employment, random, reasonable-suspicion, post-accident, and return-to-duty testing for safety-sensitive positions, with all testing conducted at the Company's expense and reviewed by a qualified Medical Review Officer.

In accordance with Montana law (MCA 16-12-108), the Company will not take adverse action against an employee for lawful use of marijuana products outside of working hours and off Company premises, unless such use affects the employee's ability to perform job duties safely. The Company maintains a zero-tolerance policy for impairment while on duty or on Company premises.

The Company's record keeping and control systems are critical components of our business and the integrity of such systems must be maintained at all times. All assets, liabilities and transactions must be accurately and completely reported in the books and supported by necessary documentation in accordance with generally accepted accounting principles. No one will ever consider concealing, falsifying, manipulating, or destroying records for the purpose of impeding or obstructing any investigation undertaken by the Company or a governmental body.

The Company believes in full, accurate, timely and understandable reporting to regulatory agencies as required by law. If any Employee has concerns or complaints regarding accounting or auditing issues, he or she is encouraged to submit those concerns under the Company's Whistleblower Policy.

The Company recognizes that our operations may uncover historic materials, artifacts, and mineral specimens that have scientific, educational or collector value. Historic materials and mineral specimens discovered during Company operations are the property of the Company or the relevant property owner as determined by applicable laws and agreements. The Company maintains a specimen collection program that documents significant finds, preserves items of particular importance, and allows for the reasonable distribution of specimens to employees, museums, educational institutions, or collectors, with releases approved by the CEO.

Employees are expected to protect Company assets and ensure their appropriate use for legitimate business purposes. Company assets include physical property, electronic resources, and intangible assets such as data, intellectual property, and business opportunities. Personal use of Company assets should be minimal and not interfere with job responsibilities. Never use the Company's assets in an illegal or improper manner or for an illegal or improper purpose.

The Company's records, reports, papers, geological data, exploration results, mining processes, and development plans are proprietary and confidential. Proprietary information, including mineral resource estimates, drilling data, assay results, metallurgical test results, and other technical, financial and business information, must be kept confidential and protected against theft, loss or misuse. Confidential or proprietary information must never be used for personal gain, including for purposes of securities trading or claim staking.

The foregoing obligations of confidentiality are subject to applicable whistleblower laws, which protect your right to provide information to governmental and regulatory authorities. Further guidance is provided in the Company's Communications and Corporate Disclosure Policy.

The Company provides information technology resources to help employees perform their jobs effectively. Company information systems are primarily for business use; limited personal use is permitted provided it does not interfere with job performance. All software must be properly licensed. The Company respects employee privacy but reserves the right to monitor system usage as needed for legitimate business purposes. Additional guidance is provided in the Company's Information Technology Policy.

Canadian and United States securities laws prohibit trading in securities of any company while in possession of material information concerning a company that has not previously been disclosed to the public. It is also illegal to "tip" or pass on inside information to any other person who might make an investment decision based on that information.

Employees are encouraged to invest in shares of the Company. Employees must, however, avoid buying or selling shares when in possession of confidential information which, if generally available, would reasonably be expected to affect the market price or value of those shares. Blackout notices will be issued to all Employees and consultants/contractors pursuant to the Company's Insider Trading Policy.

The Company is committed to ensuring that disclosure made by the Company to its shareholders and to the public in general is made in a timely manner, is full, fair, accurate and understandable, and is broadly disseminated in accordance with all applicable legal and regulatory requirements. Further guidance is provided in the Company's Communications and Corporate Disclosure Policy and Insider Trading Policy.

The Company encourages open communication and early identification of potential issues. Operational matters, including safety, health, environmental risks, and general Code violations, should be reported to your supervisor or the CEO. Financial, accounting, or audit concerns should be reported to the Audit Committee Chair. All reports will be handled confidentially. The Company prohibits retaliation against anyone who reports concerns in good faith. Reports will be retained confidentially for seven years.

Travis Naugle, CEO — Phone: +1 (406) 718-7605 — E-mail: travis@silverbowmining.com. Steve Durbin, Audit Committee Chair — Phone: +1 (917) 622-5200 — E-mail: sdurbin@quailbendcapital.com.

The Governance and Nominating Committee will review this Code annually and make a recommendation of proposed changes, if any, to the Board of Directors. This Code may be amended, modified or waived by the Board of Directors and certain waivers may also be granted by the Audit Committee. Any waiver of this Code for Employees must be approved by the Board of Directors and promptly disclosed pursuant to applicable securities laws and the rules of stock exchanges on which the Company is listed. Employees will be fully informed of any material revisions to the Code.