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WHISTLEBLOWING

Zoltav is committed to the highest standards of honesty, openness and accountability and we believe that our employees play a vital role in achieving this.

Zotlav has implemented a whistleblowing policy in the event that an employee is concerned about the conduct of someone in the organisation but is worried about raising this concern.

The policy applies to all employees of Zoltav Resources Inc. or our subsidiaries. It also applies to external consultants, contractors and agency staff while working for Zoltav or our subsidiaries.

We would expect our employees to report any suspicion of failure to comply with legal obligations, criminal offences, actions which endanger the health or safety of employees and members of the public, actions which cause damage to the environment, actions which cause financial loss or reputational damage or actions to conceal any of the above examples of misconduct.

If you are concerned that the interests of Zoltav and its subsidiaries or those of any other individual or entity are at risk then please raise your concern.

Confidentiality

If you raise a genuine concern under this policy, you will not be at risk of losing your job or suffering any form of retribution or harassment as a result. Providing you are acting in good faith, it does not matter if you are mistaken. This policy does not, however, extend to protect anyone who maliciously raises a concern that they know is untrue.

Regardless of the above assurance, we understand that you may still want to raise a concern in confidence under this policy. If you ask Zoltav to keep your identity confidential when raising your concern, we will not disclose it without your consent. But you should remember that if you do not tell us who you are, it will be much more difficult for us to investigate your concern or to give you feedback.

Confidential records will be kept of all matters raised through this policy and the appropriate committee will receive reports with an assessment of the effectiveness of the policy.

How to raise a concern

We hope that, in the first instance, you will feel able to raise a concern with your direct line manager. You can do this in writing, in person or, if you prefer, you can telephone your manager.

If, for whatever reason, you feel you cannot speak with your manager about your concern or if you think your concern has not been properly dealt with, then you should contact Kirill Abaryshev, Counsel for Zoltav, who is responsible for the administration of this policy.

Telephone: +7 (495) 230 0018

Email: abaryshev@zoltav.com

Address: Zoltav Resources Inc. Moscow Representative Office, Sadovnicheskaya str, 4/1, Moscow 115035, Russia

Once you have raised your concern, we will look into it to assess what action, if any, should be taken. Depending on the nature of your concern, this may mean an internal inquiry or a more formal investigation. We will tell you who your point of contact will be and whether we will need further assistance from you. We may ask you how you think your concern should best be dealt with. If you have a personal interest in the matter we would ask that you tell us at the outset. Whilst we will try to give you as much feedback as possible, we may not be able to give you specific details as this could infringe upon the privacy of another individual.

We cannot guarantee that we will respond to all concerns in the way that you might wish, but we will try to handle the matter fairly and properly.