CODE OF
CONDUCT

CONTENTS
Message from the CEO
1. INTRODUCTION
2. PURPOSE, VISION AND VALUES
3. COMPLYING WITH THIS CODE
4. STANDARDS OF BEHAVIOURS• General Standards• Health & Safety• Environment• Diversity & Inclusion• Human Rights• Communities• Anti-Bribery and Corruption• Conﬂicts of Interest• Data Privacy and Cybersecurity• Conﬁdential Information• Trading in Allkem Shares• Communications and Disclosures• Allkem Assets• Competition
5. ADDITIONAL STANDARDS FOR OUR DIRECTORS
6. NON-COMPLIANCE WITH THIS CODE
• Speaking Up• Quick Test
• Raising a concern• Consequences of contravention
7. COMMUNICATION & TRAINING
8. MONITORING AND REVIEW

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MESSAGE
FROM THE CEO
At Allkem we have a vision to create a sustainable, large scale, global lithiumchemicals business to power the future. It is an exciting time to be involved in anindustry that will lead the change to a sustainable energy future.
Our vision will only be achieved where we all demonstrate behaviours that areconsistent with our core values and the expectations of our key stakeholders.
The key behaviours that we are all expected to demonstrate in our day to day roles
are set out in this Code of Conduct. It applies to all directors, oﬃcers, employees,
contractors and service providers, regardless of their role or location within
Allkem. We all have a shared responsibility to make our company a great place towork and create a culture of trust and care for one another.
I encourage you all to read this Code of Conduct and model your behaviours atwork on the expectations set out within it. I believe Allkem will be a leader in thelithium chemicals industry, and our people will lead the way in terms ofdemonstrating appropriate behaviours whatever the challenges ahead.
Thank you for your support.

Martín Pérez de Solay

Managing Director & CEO03

1. INTRODUCTION
At Allkem we are committed to conducting our business activities fairly, honestly
and with integrity in compliance with applicable laws. It is the responsibility of all
our people to ensure ethical conduct is recognised and valued throughout Allkem.
This Code of Conduct (Code) sets out our expectations of appropriate conduct by
you in a variety of contexts and outlines the minimum standard of behaviour we
expect. These behaviours are underpinned by the Allkem Values and reﬂect the
expectations of our customers, investors, regulators, and the community.
This Code brings together key elements of our corporate policies, procedures andstandards which collectively outline our expectations about how you will behave
and conduct yourself when working for, or with, Allkem. Compliance with thisCode and our policies, standards and procedures is a condition of working for, orwith, Allkem.

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2. PURPOSE,
VISION AND VALUESPURPOSE

Producing core materials that are fundamental for decarbonisation.

VISION

To be a top three global lithium chemicals producer.

VALUESWe are committed to conducting our business activities in accordance with thefollowing values and behaviours which underpin our work culture and how wework together to achieve our Vision:

Respect

We foster trusted relationships with our collaborators, thediﬀerent communities, and our business partners.

Inclusion

We promote a working environment where everyone is treatedwith respect and diﬀerences are celebrated and considered.

Empowerment

We encourage all our collaborators to live to their fullest potential
and to be proud of the role they play.

Commitment

We keep our promises, reinforcing our reputation as trustworthyand qualiﬁed partners.

Integrity

We are consistent with our core values in all our tasks and in ourinteractions with others.

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3. COMPLYING WITH THIS CODE
Who must comply
Compliance with this Code is mandatory for every individual working for, or
engaged by, Allkem at any level or grade, wherever located, including all:. our directors, oﬃcers, executives, managers, employees
and other personnel (Employees);. third party representatives who interact with others on
our behalf; and. our contractors and suppliers (Contractors),(collectively referred to in this Code as you).
Contractors may also follow their own code of conduct where the relevant
standard of behaviour is the same as, or more onerous than, this Code.
References in this Code to Allkem, we, us or our are to Allkem Limited and each of its
subsidiaries worldwide (including subsidiaries which are joint venture companies).
In this Code a reference to an Allkem policy includes its associated standards
and procedures.

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The role of our leaders to assist compliance
We know the standard we walk by is the standard we accept. That’s why, if you
are responsible for managing Allkem Employees and Contractors, it isimportant you act as a role-model of our Values by:. ensuring the eﬀective implementation, promotion andsupport of this Code in your areas of responsibility;. ensuring your team members understand and comply
with the requirements of this Code and receive
appropriate training in respect of it;. embedding our Code into day-to-day activities andexisting processes;. fostering an inclusive culture where everyone feels
comfortable to ask questions or speak up without fearof retribution;. reporting any ethical issue or suspected contraventionof this Code; and. taking appropriate and proportionate permitted
disciplinary action against any member of your team
who contravenes this Code.

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4. STANDARDS OF BEHAVIOUR
General Standards
You must at all times act:

. in accordance with Allkem’s Values;. honestly, ethically and responsibly, and with high standards of personal
integrity; and. in accordance with all applicable laws and regulatory requirements of

the jurisdictions in which we operate (and if the requirements of thisCode diﬀer from the requirements of those applicable laws, you must
act in accordance with the more onerous requirement). You should beaware that the laws in the places where you may work for, or with, Allkem
may diﬀer and you may be subject to the laws of more than one placeat the same time.

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PRINCIPLE 1: Health & Safety

A safeworkplace
You should be able to go to work without fear of injury or illness. We arecommitted to protecting the health and safety of all Employees,
Contractors and others involved in our business operations. We are also
committed to providing a workplace which enables Allkem Employees andContractors to perform their duties eﬀectively without presenting a risk tothemselves or others. Further detail is set out in our Health and Safety Policy.
You must always act in a manner which complies with that policy.

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PRINCIPLE 2: Environment

Caring for
the Environment
We are committed to conducting our activities in an environmentally
responsible manner by understanding and minimising the potential impactsof our operations on the environment. Further detail is set out in ourEnvironmental Policy.
You must always act in a manner which complies with that policy.

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PRINCIPLE 3: Diversity & Inclusion

Treat others with
fairness and respect
Bullying, harassment or discrimination of any kind towards others is neveracceptable, and we will not tolerate them occurring, in our business or bythose we do business with. We know that our diﬀerences related to thecolour of the skin, gender, age, nationality, political or religious beliefs or
how we self-identify, does not aﬀect our ability to do our job.
We strive to attract and retain quality people to enhance a culture thatcelebrates diversity, empowers personnel and promotes integrity in all
activities. The principal criteria for selection and promotion of people towork within the Company is their overall relative prospect of adding value tothe Company and enhancing the probability of achievement of theCompany’s objectives. Further detail is set out in our Diversity Policy.
You must always act in a manner which complies with that policy and, inparticular, you must at all times treat fellow Allkem Employees andContractors with respect and not engage in bullying, harassment or
discrimination of any kind.

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PRINCIPLE 4: Human Rights

Respect for the human rights
of all people
We support and respect the protection of human rights across all ouroperations and associated activities. We place particular emphasis on theevaluation of labour rights and labour conditions in our operations andour supply chain, and report on these annually. We work to ensure thatthese principles and rights are respected for our employees and all those
who work in our supply chain or are impacted by our operations. Further
detail is set out in our Human Rights Policy.
You must always act in a manner which complies with that policy.

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PRINCIPLE 5: Communities

Improving the wellbeing of thecommunities in which we operate
Our shared value philosophy seeks to deliver sustained long-term value forboth the local communities in which we operate and our operations. We
believe that we have an obligation to support and contribute tocommunities (both socially and economically) in the regions in which we
operate – with the aim to minimise adverse impacts and enhance positive
impacts from our business operations.
Allkem is committed to creating value for our stakeholders in a manner thatencourages high standards of empathy, respect, transparency, and ethics ineverything we do. We take proactive steps to achieve sustainable
development in connection with our operations.
Further detail is set out in our Sustainable Development Policy andCommunity Policy.
You must always act in a manner which complies with those policies.

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PRINCIPLE 6: Anti-Bribery and Corruption

We prohibit bribery andcorruption in all our activities
Bribery and corruption are never acceptable, and we will not tolerate themoccurring, in our business or by those we do business with.
Whenever you are acting for or on behalf of Allkem you must never oﬀer,
solicit, give or accept a beneﬁt as an inducement or reward for an improper
act. You must never give or accept gifts or hospitality to obtain an improper
advantage, or as an inducement or reward for something given in return.
Allkem is committed to maintaining accurate and complete books andrecords for all ﬁnancial transactions and to ensuring accurate andtransparent ﬁnancial reporting. All expenditure must be supported bydocuments that completely, accurately and properly describe such
expenditure and the reason for the expenditure must be speciﬁcally recorded.
Further details are set out in our Anti-Bribery and Corruption Policy
and Anti-Bribery and Corruption Standard. You must comply with those
documents.

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PRINCIPLE 7: Conﬂicts of Interest

Acting in Allkem’s
best interests
You should not engage in activities (including holding or dealing in assets)that involve, or could appear to involve, a conﬂict between your personal
interests and the interests of Allkem. Such circumstances could compromise
or appear to compromise your ability to make impartial business decisions.
We cannot avoid all circumstances in which a conﬂict of interest may
arise, but we can take steps to ensure we always act objectively andwithout bias. We do this by disclosing and managing potential or existing
conﬂicts of interest. Further details are set out in the Conﬂict of Interest
Standard.
You must comply with that standard including, if you are faced with aconﬂict of interest, reporting it to your manager.

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PRINCIPLE 8: Data Privacy and Cybersecurity

Protecting
personal information
We have signiﬁcant obligations under privacy legislation and otherapplicable laws to protect the privacy of individuals. We protect the data
entrusted to us by handling it properly, using it only for the intended andauthorized purposes, and always considering the full rights of the data owner.
We take these obligations and the protection of personal information
seriously. We are committed to increasing cybersecurity awareness at
Allkem and to taking appropriate measures to protect our technology,
systems and digital assets, including the information we hold, fromcybersecurity breaches.
Further information can be found in the Privacy Policy, Privacy Manual andthe Information Security Policy.
You must always act in a manner which complies with those documents.

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PRINCIPLE 9: Conﬁdential Information

Protecting
conﬁdential information
While working for or with us, you may have access to or become aware of
conﬁdential information about Allkem. This includes any information which
is not generally available to the public concerning our activities, strategies,
results or plans. Information owned by or concerning a third party that has
been provided to Allkem or to which Allkem has been given access, may also
be conﬁdential.
If you have access to conﬁdential information you must:. maintain the conﬁdentiality of that information and not disclose it outside
Allkem without proper authorisation;. only access that information for, or in connection with, your role andresponsibilities within Allkem;. ensure that the information is only used for authorised purposes and isprotected from theft, unauthorised or inappropriate use (including for
personal gain) and unauthorised disclosure; and. report any loss or unauthorised disclosure of such information promptly
to your manager.

You must also be aware of and comply with the conﬁdentiality obligations
set out in your employment or engagement agreement with us. Thoseagreements usually provide that your conﬁdentiality obligations continue toapply to you after your employment or engagement with us ceases.
If you are unsure whether information is of a conﬁdential nature or what
your obligations are with respect to information to which you have access,speak to your manager or a member of the Allkem Legal Department.

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PRINCIPLE 10: Trading in Allkem Shares

No share trading whilst
in the possession of inside information
It is unlawful to deal in the shares of a company while in possession of “inside
information”. This is known as “insider trading” and is a serious oﬀence underthe Australian Corporations Act and equivalent international laws.
INSIDE INFORMATION is information about a company that is not generally
available to the public and which a reasonable person would expect to havea material eﬀect on the price of a company’s shares. Inside information can
include information about sales, earnings or other important ﬁnancial
information, signiﬁcant transactions, changes in key personnel or the entry
into a new market.
If you have access to or become aware of inside information relating toAllkem, it is unlawful for you to buy, sell or otherwise deal in Allkem´sshares. It is also unlawful in those circumstances to communicate suchinformation to anyone else who may deal in our shares.
The penalties for insider trading are severe and can include
imprisonment.
Our Trading Policy provides further details in relation to
the trading of Allkem’s securities. You must comply
with that policy.

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PRINCIPLE 11: Communications and Disclosures

Apply regulations
about sharing information
As Allkem is a publicly listed company it has extensive obligations inrelation to disclosure of information about the company and its
operations. We are required to disclose information in a timely, accurate,consistent, complete and fair manner so investors can make informed
decisions about investing in our shares.
We have adopted a Disclosure Policy to assist in compliance with theseobligations.
The policy also sets out who can disclose information to the public about,and speak publicly on behalf of, Allkem including with respect tocommunications with stock exchanges, regulatory bodies, media
organisations, stock brokers, ﬁnancial analysts, investors or other membersof the public. If you receive a request for information about Allkem and you
are not authorised by the policy to respond to the request you should
promptly refer it to your manager or Allkem’s Investor Relations andCorporate Aﬀairs Manager.
You must always act in a manner which complies with that policy.
Allkem has social media accounts which it uses to share information fromtime to time about the company and its operations. Those accounts aremanaged by Allkem’s Investor Relations team. When using your personalsocial media accounts, you should refrain from disseminating information
about Allkem (including photos).

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PRINCIPLE 12: Allkem Assets

Protecting and using
Allkem assets responsibly
While working for or with us, you may be able to access and use ourinformation systems, intellectual property, equipment, services and otherassets. You must do so in an ethical and secure manner and in accordancewith the obligations set out in your employment or engagement agreement,
all Allkem policies (including this Code) and all applicable laws. Allkem assets areto be used for Allkem business only and not for any private or other purpose.
The use of Allkem assets oﬀ Allkem’s premises is prohibited without
approval. The use of mobile phones and laptops oﬀ Allkem’s premises for
Allkem business is deemed to be approved unless you are otherwise
informed. If approval is (or is deemed to be) granted, you must takeresponsibility for maintaining, replacing, and safeguarding the assets andfollowing any special directions or conditions that apply. Assets covered bythese requirements include physical and non-physical property, such as
equipment, inventory, technology, money, intellectual property andCompany information and data.
If you use Allkem assets other than in accordance with theforegoing, you could face disciplinary and/or legal action.

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PRINCIPLE 13: Competition

Comply with the laws that regulate
anti-competitive behaviour
Most jurisdictions in which we operate have competition laws designed toprotect against anti-competitive behaviour. These laws are designed tostop practices that restrain trade or restrict free and fair competition,such as price ﬁxing, cartels, market sharing, bid rigging or abuse of adominant market position.
Breach of competition laws can result in serious consequences for Allkem,
our employees and other individuals who may be involved. Penalties can
include signiﬁcant ﬁnes and imprisonment. Businesses and/or consumers who
are damaged by unlawful conduct may be able to sue to recover damages.
Allkem does not, and you must not at any time, engage in anti-competitive
behaviour in contravention of applicable competition laws. In all dealings
with Allkem’s competitors, joint venture partners, customers and suppliers
you must conduct yourself fairly, ethically, honestly, and respectfully, in amanner that does not breach applicable competition laws.
Without limiting your obligations:. you must not misrepresent our products, services or prices and must
not make false claims about those of our competitors; and. purchasing decisions must be based on such commercially competitive
factors as quality, price, reputation and reliability.

For further information please speak with a member of the Allkem Legal
Department or the Allkem Compliance Department.

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5. ADDITIONAL STANDARDSFOR OUR DIRECTORS
Directors have additional obligations under law, in addition to the standards
outlined above. Accordingly, if you are an Allkem director:. you must act honestly, in good faith and in the best interests of Allkem
as a whole;. you have a duty to use due care and diligence in fulﬁlling the functionsof oﬃce and exercising the powers attached to that oﬃce;. you must use the powers of oﬃce for a proper purpose, in the bestinterests of Allkem as a whole;. your primary responsibility is to Allkem’s shareholders as a whole but
you should, where appropriate, have regard for the interests of all
stakeholders of Allkem;. you must not make improper use of information acquired as a director
or take improper advantage of your position of director; and. you must not allow personal interests, or the interests of any
associated person or company, to conﬂict with the interests of Allkem.

226. NON-COMPLIANCE
WITH THIS CODE
SPEAKING UP

If you become aware of behaviour which is or may be a breach of this Code, youhave a responsibility to speak up. Speaking up about that behaviour can be toughbut ignoring it may only serve to make the problem worse.

QUICK TEST

If you are in doubt about whether you should speak up, ask yourself whether the
behaviour:

Safetycould directly or indirectly endanger you or others or cause
them physical or mental harm?

Law

Is lawful and consistent with our policies?

?

Conscience

does it feel “right” and ﬁt with my personal values and those of
the company? If it feels wrong, then it probably is wrong.

Media

how would I feel if the behaviour appeared in the media?

Community

is it fair to our stakeholders?

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RAISING A CONCERN

You don’t need to be directly aﬀected by a non-compliance issue to raise it, andthere are several ways you can do so.
Allkem’s Whistleblower Policy contains detailed information about raisingconcerns. It sets out the various ways in which concerns can be raised bothinternally and externally and the protections available to individuals doing so.
Persons or entities to whom concerns can be raised under the Whistleblower
Policy include the directors, the Chief Legal Oﬃcer, the Company Secretary, anotheroﬃcer or senior manager of Allkem and the Ethics Line (openly or anonymously).
Further detail is contained in the Whistleblower Policy.
You may also choose to raise a concern with your manager or a member of the
Human Resources Department. However doing so in this manner may not aﬀord
you the same protections prescribed by law as you may have for disclosures madein accordance with the Whistleblower Policy.
We know that speaking up takes both courage and integrity, and we respect thisby treating your concern sensitively and committing to investigate whereappropriate. All reports will be treated conﬁdentially, and you will be protectedfrom any form of retaliation or disadvantage arising from disclosing in good faithan actual or possible contravention of this Code.
Material contraventions of this Code will be reported to the Board.

CONSEQUENCES OF CONTRAVENTION

Contraventions of this Code may result in disciplinary action
including reprimands, formal warnings, demotions or
termination of your employment or engagement.
Legal action may also be taken.

247. COMMUNICATION & TRAINING
This Code is available via the Company’s intranet and on the Company’s external
website at www.allkem.co.
We hold periodic training sessions for Allkem oﬃcers, employees and otherpersonnel regarding compliance with this Code.
If you have a query about this Code or need further information, please contact
your manager, Human Resources, the Legal Department or the ComplianceDepartment.

8. MONITORING AND REVIEWThis Code will be reviewed periodically to ensure that it is operating eﬀectively andto identify if any changes are required. Suggestions for improvements oramendment to the Code can be made at any time.
Approved by the Allkem Board
December 1st 202225