Exhibit 99.9



Mountain
Province Diamonds Inc.



Business
Conduct Policy










| | A. | Ethical Behaviour
| | -- | -----------------



| | 1. | Legality
| | -- | --------



| | 2. | Honesty
| | -- | -------



| | 3. | Fair dealing
| | -- | ------------



All activities by Mountain Province Diamonds
Inc (“MPV” and the “Company”) and its directors, officers, employees and consultants must be lawful.



Lawfulness, however, is merely a starting point.
It is equally important that all activities be conducted in an ethical manner. Ethical conduct means conduct that is honest, fair
and free from deception and impropriety. Employees and other representatives of MPV must, at all times, act in accordance with
a high standard of ethical behaviour and with constant regard for MPV’s reputation. As discussed in the next several pages,
these requirements apply to dealings with MPV, fellow employees, shareholders, other businesses and the community at large.



Ultimately, each individual should test his
or her own behaviour by asking: “Is there any reason why I would not want another person - MPV, a co-worker, a business associate,
and any government - to be fully aware of my conduct and motives?” If this question causes any discomfort, the individual
should reconsider his or her conduct.



| | B. | Ethical Business Practices
| | -- | --------------------------



For MPV’s reputation in the business
community to be maintained, all dealings on MPV’s behalf must reflect high standards of ethical behaviour. In particular,
the following specific principles must be observed:



| | 1. | Compliance with Laws
| | -- | --------------------



All directors, officers, employees
and consultants must be aware of and comply with all relevant laws and regulations in all jurisdictions in which MPV conducts business.
Individual directors, officers, employees and consultants have a duty to inform themselves of any laws relevant to their particular
activities. Anyone with questions regarding legal issues should consult with the CEO, who will consult with MPV’s legal counsel.



| | 2. | Integrity in Business Dealings
| | -- | ------------------------------



Directors, officers, employees and
consultants must act with integrity in dealings with all persons inside and outside the Company, including government officials,
customers, suppliers and members of the community. Employees must follow established standards in procurement, and must treat tenderers
fairly and equally.











| | 3. | Gifts
| | -- | -----



No person may give to outside companies
or individuals, or accept from them, any material gift or extravagant entertainment, or any similar benefit. (A “material”
gift is one of such value that it constitutes a personal enrichment for the recipient such that it could be a factor in influencing
that person’s behaviour. Entertainment will be considered “extravagant” if it would appear excessive to an objective
observer and would typically be of a value greater than $500). Employees must properly record in MPV’s accounts any amounts
spent on gifts or entertainment.



| | 4. | Questionable or Improper Payments
| | -- | ---------------------------------



Where commissions, consultant fees,
retainers and similar payments are required to be made and can be justified in the normal course of business, those payments must
be clearly commensurate with the services performed and must be properly recorded in the accounts of MPV.



| | 5. | Political Donations
| | -- | -------------------



It is MPV’s policy not to make
political donations of any description.



| | 6. | Compliance with Accounting Policies
| | -- | -----------------------------------



Employees must comply strictly with
prescribed accounting policies, audit procedures and other such controls. All accounts must properly describe and accurately reflect
the transactions recorded and all assets, liabilities, revenues and expenses must be properly recorded in the books of MPV. No
secret or unrecorded funds or other assets are to be established or maintained.



| | 7. | Contract Workers
| | -- | ----------------



The Company considers that the compliance
obligations arising out of this Policy apply not only to employees of the Company, but also to independent contract workers to
the extent that they conduct activities on the Company’s behalf. The Company therefore expects all such contractor personnel
to familiarise themselves with this Policy, and to comply with it, in the same manner as is expected of MPV directors, officers
and employees.



| | 8. | Business Associates
| | -- | -------------------



The Company will make all reasonable
efforts to promote the application of these ethical business practices by our third party suppliers.



| | C. | International Business
| | -- | ----------------------



MPV’s international activities results
in increased exposure to legal and ethical issues.



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| | 1. | Compliance with Anti-Bribery Legislation
| | -- | ----------------------------------------



MPV is subject to legislation in
Canada that prohibits corrupt practices in dealing with foreign governments. The Canadian Corruption of Foreign Public Officials
Act, makes it an offence to make or offer a payment, gift or benefit to a foreign government official in order to induce favourable
business treatment, such as obtaining or retaining business or some other advantage in the course of business. Violation of this
legislation may result in substantial penalties to MPV and to individuals.



MPV, as well as individual employees,
must take all reasonable steps to ensure that the requirements of this legislation are strictly met. No payments, material gifts
or other benefits are to be given, directly or indirectly, to foreign government officials, political parties or political candidates
for the purpose of influencing government decisions in MPV’s favour. Furthermore, no such payments are to be made to agents
or other third parties in circumstances where it is likely that part or all of the payment will be passed on to a foreign government
official, political party or political candidate. For the purpose of this paragraph, a material gift or benefit has a value in
excess of $500.



| | 2. | Facilitation Payments
| | -- | ---------------------



There are certain types of payments
to foreign government officials that are allowed under Canadian legislation, called “facilitation” or “facilitating”
payments. These are small payments or tips that are accepted custom in certain foreign countries in the context of having routine
administrative actions performed by government officials. Employees should be aware that such payments are permissible only under
very limited circumstances and must be properly documented. As well, they must advise the CEO or CFO in advance of any anticipated
payments and provide written request for reimbursement of any such payment. If there are any questions regarding the permissibility
of any particular payment, advice should be sought from the CEO or CFO. Moreover, employees must ensure that any such payments
are properly recorded in accordance with the Company’s accounting procedures.



A copy of the Canadian foreign corrupt
practices legislation is available from the Corporate Secretary. Anyone with questions regarding these legal issues should consult
the CEO or CFO.



| | D. | Personal Conduct
| | -- | ----------------



| | 1. | Work-related Conduct and Conflicts of Interest
| | -- | ----------------------------------------------



MPV employees must comply with the
standards of ethical behaviour in all aspects of their employment. This includes their dealings with people outside the Company
as well as their relationships with their fellow employees and with MPV as their employer. In addition, MPV expects that employees
will act with loyalty to the Company at all times.



In particular, individuals must not:



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| | (i) | Pursue personal gain or advantage from their employment activities;
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| | (ii) | Misuse Company resources, including computer systems;
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| | (iii) | Engage in insider trading;
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| | (iv) | Compromise the confidentiality of corporate information; and
| | ---- | ------------------------------------------------------------



| | (v) | Permit any actual or perceived conflict of interest between their personal interests and those
of the Company. Employees must not enter into outside activities, including business interests or other employment, that might
interfere with or be perceived to interfere with their performance at MPV or otherwise compromise their duty of loyalty to MPV.
| | --- | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| | 2. | Personal Conduct
| | -- | ----------------



In general, MPV does not wish to
dictate the personal conduct of individual employees outside working hours. Nevertheless, it expects employees to act lawfully
at all times and to conduct their personal affairs as good and responsible citizens, in such a manner that reflects well on MPV.



| | E. | Employment Practices
| | -- | --------------------



| | 1. | MPV recognizes that it must earn the loyalty that it expects from its employees. MPV is committed
to treating its employees ethically and fairly. In particular, MPV strives to ensure the following:
| | -- | -----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| | (i) | No discrimination on the basis of gender, disability, age, marital status, sexual orientation,
religious belief, race, ethnicity, ancestry or place of origin;
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| | (ii) | Fair and competitive compensation;
| | ---- | ----------------------------------



| | (iii) | Fairness in performance appraisals and job advancement;
| | ----- | -------------------------------------------------------



| | (iv) | Protection of employees from harassment; and
| | ---- | --------------------------------------------



| | (v) | Confidentiality of employee records.
| | --- | ------------------------------------



| | 2. | All officers must maintain and promote these principles in their hiring practices and in their
relationships with other employees.
| | -- | ----------------------------------------------------------------------------------------------------------------------------------



| | F. | Health, Safety and Environment
| | -- | ------------------------------



| | 1. | Effectiveness in occupational health, safety and environmental standards is an essential part of
achieving efficiency and profitability in the mining industry. MPV will therefore work at continuous improvement in these areas
and will be guided by the following principles:
| | -- | --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| | (i) | Creating a safe work environment;
| | --- | ---------------------------------



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| | (ii) | Minimizing the environmental impacts of its activities;
| | ---- | -------------------------------------------------------



| | (iii) | Building co-operative working relationships with local communities and governments in the Company’s
areas of operation;
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| | (iv) | Reviewing and monitoring environmental and safety performance; and
| | ---- | ------------------------------------------------------------------



| | (v) | Prompt and effective response to any environmental and safety concerns.
| | --- | -----------------------------------------------------------------------



| | G. | Disclosure of Information
| | -- | -------------------------



| | 1. | All corporate information is the property of MPV. Corporate information includes trademarks, patents,
software developments and applications, strategic and operational knowledge and financial information. It also includes any confidential
information received by MPV from third parties.
| | -- | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| | 2. | Employees are in a position of trust with respect to corporate information in the same manner as
with any other corporate property. Employees must take care to protect the confidentiality of corporate information. In particular:
| | -- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| | (i) | Employees must not use corporate information for personal gain;
| | --- | ---------------------------------------------------------------



| | (ii) | Employees may not disclose corporate information other than for legitimate purposes and with appropriate
safeguards, unless written approval is obtained from the CEO or CFO;
| | ---- | -----------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| | (iii) | Media and investor communications are to be handled by the CEO or CFO;
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| | (iv) | Employees must not disclose undisclosed corporate information.
| | ---- | --------------------------------------------------------------



| | H. | Ensuring Compliance with this Policy
| | -- | ------------------------------------



| | 1. | Compliance
| | -- | ----------



| | (i) | As part of its efforts to ensure compliance with this Policy, MPV requires that each employee complete
an annual Compliance Certificate certifying compliance with this Policy. Employees whose positions may include involvement with
foreign operations may be asked to complete more frequent Compliance Certificates so as to ensure corporate compliance with anti-bribery
legislation. Completed certificates are to be returned directly to the Corporate Secretary.
| | --- | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| | (ii) | Any proposed non-compliance such as a proposed material gift, must be pre-approved by the CEO.
| | ---- | ----------------------------------------------------------------------------------------------



| | (iii) | The Company requires that employees report any observed breaches of this Policy to the CEO or CFO.
| | ----- | --------------------------------------------------------------------------------------------------



| | (iv) | An employee or consultant who violates this Policy may face disciplinary action up to and including
termination of employment, in the case of an employee, and, in the case of a consultant, termination of the consulting contract
with the Company. Violation of this Policy may also cause violation of certain laws. If it is discovered that laws have been
violated, this matter may be referred to the appropriate regulatory authorities. Questions with respect to this Policy may be referred
to the Company's Secretary.
| | ---- | -----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



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