ETHICAL CONDUCT

Bisha-BookNevsun’s Code of Ethics defines our commitments to ethical and sustainable social and environmental business practices wherever we operate. To emphasize and promote the importance of ethical conduct, Nevsun’s board of directors (the “Board”) adopted a Code of Ethics applicable to employees, contractors, officers and directors of Nevsun and each of its subsidiaries. The purpose of this code is to promote honest and ethical conduct, full, fair, accurate, timely and understandable disclosure, and compliance with applicable governmental rules and regulations. There is accountability for any violations of the Code. To ensure and monitor compliance with the Code, the Company circulates a copy of the Code to each new employee, requesting a signature acknowledging its receipt. The Code of Ethics was last revised and updated in April 2015 and is available on our website here.

Embedded in the Code of Ethics are provisions addressing ethical conduct, conflicts of interest, compliance and disclosure obligations, financial reporting, accountability, violations of the Code, bribery and corruption, health, safety, and environment, and human rights.

WHISTLEBLOWER POLICY

Our Whistleblower Policy enables all employees, officers, directors, contractors, and subcontractors to raise concerns regarding the Company’s accounting, internal accounting controls, auditing matters or violations or suspected violations of its Code of Ethics without fear of harassment, retaliation, or adverse employment consequences.

Reports are directed to the Chairman of Nevsun’s Audit Committee or to an independent, externally managed hotline service to handle complaints on a confidential and anonymous basis. The hotline service is available 24/7. Details regarding the Company’s Whistleblower Policy are contained within the BMSC Employee Handbook and are publicly accessible on our Corporate website here.

In addition to Nevsun’s Code of Ethics and Whistleblower Policy, BMSC in Eritrea adheres to numerous policies in environmental management, health and safety, employee relations, and social responsibility.

VISIONS & VALUES

Nevsun’s vision is to maximize long term community benefits and shareholder value in the responsible development of mineral resources wherever we operate. To accomplish this vision, the Company endorses and promotes the values statement below:

SAFETY

We adhere to high safety standards and procedures and protocol for our employees, contractors, subcontractors, communities and partners. We continually seek better ways to enhance safety culture and continually strive towards a zero target for accidents and incidents.

HUMAN RIGHTS

We believe in treating everyone equally with dignity and respect. We support inclusiveness and diversity of opinions in the decision-making process.

INTEGRITY

We believe that maintaining our social license is entirely dependent on our ability to cultivate mutual ongoing respect through honesty and accountability in our interactions with our diverse stakeholders in the communities in which we operate.

CREATING SHAREHOLDER VALUE

We focus on cost-effective operational governance and financial management excellence in order to maximize shareholder investment returns.

SUPPORTING OUR COMMUNITIES

We strive to make a positive long term sustainable impact in the communities in which we operate. This includes local opportunities for employment, training and advancement, and community development projects.

SUPPORTING THE ENVIRONMENT

We are committed to the mitigation and remediation of all environmental impacts through the construction, operation, and closure plan aspects of our activities. We undertake numerous studies and action plans throughout the project cycle to ensure the diverse biological ecosystems where we operate are protected for future generations.

GOVERNANCE STRUCTURE

The Board has the responsibility to oversee the conduct of the management of the Company. The fundamental objectives of the Board are to oversee the Company’s strategic direction, enhance long-term shareholder value, ensure the Company operates in a reliable, safe manner, and that it meets its obligations on an ongoing basis. The Board is accountable to, and considers the legitimate interests of, our shareholders and other stakeholders such as government authorities, employees, contractors, customers, communities, and the public. The Board, through the Chief Executive Officer, sets the standards of conduct for the enterprise, provides direction and oversight, approves strategic plans presented by senior management, and evaluates the performance of senior management. Nevsun’s independent directors have a wide base of experience and are very familiar with the many challenges related to mining and operating in geographically diverse jurisdictions. The Board members have a broad range of skills, experience and perspective doing business in developing countries having held senior leadership positions in the mining, accounting, engineering or legal professions throughout their careers.

The Nevsun Board has six committees (the “Board Committees”), including the [1] Audit Committee, [2] Corporate Governance and Nominating Committee, [3] Human Resources Committee, [4] Social, Environmental, Health & Safety Committee, [5] Special Committee, and [6] Litigation Committee.

In 2014, the Nevsun Board was comprised of six male members; five of whom were independent, non-executive directors, including the Chairman of the Board.