Ethical Conduct

Royal Gold strives to be a trusted steward of shareholder capital and a valued partner to operating companies by maintaining the highest standards of business ethics and personal integrity.

Our Code Of Business Conduct And Ethics (Code of Conduct) requires employees to adhere to principles that align the interests of Royal Gold with those of our shareholders. The Code of Conduct mandates:

• honest and ethical conduct

• full, fair, accurate, timely, and understandable disclosures

• compliance with laws, rules, and regulations

• avoidance of conflicts of interest

• protection of proprietary information and other assets

• prompt internal reporting of and accountability for code violations

The Code of Conduct is reviewed annually by the Compensation, Nominating and Governance Committee and the Board of Directors and is updated when necessary to align with corporate best practices. Employees are required to affirm their understanding of these principles on an annual basis. Employees can report suspected violations to their supervisor or any member of executive management or anonymously through our whistleblower hotline. The Code of Conduct expressly prohibits retaliation against employees who report suspected violations in good faith.

Our Whistleblower Policy requires all employees, officers, and directors to report any questionable accounting or auditing matters that come to their attention. Employees can report matters to their supervisor or any member of executive management or anonymously through our whistleblower hotline. The policy expressly prohibits retaliation against employees who report matters in good faith.

Our Anticorruption Policy is designed to ensure that Royal Gold does not receive an improper advantage in its business dealings and maintains accurate books and records. Employees and others working on our behalf are prohibited from offering or giving anything of value to foreign officials or others to obtain an improper benefit.