Code of Ethics

Values

We believe that a Code of Ethics is not an after-thought or embellishment to our Company’s values, but the clear and uncompromising expression of those values. Our Code of Ethics sets the standard for achievement using qualitative, rather than quantitative, measures.

Code of Ethics

The Golden Phoenix Code of Ethics is intended to:

• Provide a framework for professional behavior;
• Define high standards of practice;
• Offer a benchmark for self-evaluation; and
• Assign personal and corporate responsibility.

Commitment

Golden Phoenix is dedicated to doing what is right, always. Doing what is right means making the ethical choice in both routine and challenging situations. Our commitment to ethical choices is based on six core values.

Core Values

It is up to all of us who work for and with Golden Phoenix to apply these values in a common sense way to everything we do:

• Be honest and direct in our interactions
• Produce quality work to the best of our abilities
• Take responsibility for our actions
• Keep to our word and follow though
• Be a team player working for the common good
• Uphold the integrity of the Company

With these values as our ethical guideposts, we are able to define our role within the context of broader social values. Golden Phoenix is committed to the following principals, which it embraces as its social responsibility to its various constituents:

Shareholders

We will strive for profits that are ethically achieved while communicating clearly, consistently and openly.

Employees

We will seek to provide a safe, stimulating and satisfying workplace at the office and in the field.

Host Communities

We will seek to create quality jobs, contribute to the local tax-base, support local improvement programs, and promote balanced development through education and donations.

Environment

We will seek to protect and restore our mine sites and strive for optimal stewardship over the mineral wealth they contain.