Exhibit 19.1

100 Washington Street, St #100, Reno, NV 89503

This Insider Trading Policy (this “Policy”) provides guidelines with respect to transactions in the securities of American Battery Technology Company (“ABTC”) and the handling of confidential information about ABTC, its subsidiaries, and the companies with which ABTC does business. ABTC has adopted this Policy to promote compliance by all Company employees, consultants and other service providers with federal and state securities laws that prohibit certain persons who are aware of material, nonpublic information (“Insider Information,” further defined below) about a company from: (i) trading in securities of that company; or (ii) providing Insider Information to other persons who may trade on the basis of that information. Employees or consultants who trade on Insider Information (or tip such Insider Information to others) can be personally liable for damages totaling up to three times the profits made or the loss avoided by the individual trading with inside information. Insider trading is also a crime that can result in a criminal fine (no matter how small the profit) of up to five million dollars and a jail term of up to twenty years, as well as penalties described below under the heading “Consequences of Violations.”

The Securities and Exchange Commission (“SEC”) is the federal agency charged with enforcing insider trading laws in the United States. The SEC vigorously pursues insider trading violations and can detect violations using advanced technologies. The SEC’s authority to initiate insider trading investigations includes the ability to obtain the Company’s employee and consultant records, to access individual’s bank accounts and phone records, to obtain broker’s records, etc. An SEC investigation can be triggered through a variety of actions, including by an individual’s unusual trading activity, trading volume, the timing of trades that coincide with important company changes, or simply an anonymous tip to the SEC.

This Policy applies to ABTC and all its subsidiaries (collectively, the “Company”). This Policy applies to all officers of the Company, all members of the ABTC’s and its subsidiaries’ Boards of Directors, and all employees and independent contractors and interns of the Company. This Policy also applies to Family Members, other members of a person’s household and entities controlled by a person covered by this Policy, as described below.

If you are aware of Insider Information related to the Company, you may not directly, or indirectly through Family Members or other persons or entities:

Engage in transactions in ABTC securities, except as otherwise specified in this

100 Washington Street, St #100, Reno, NV 89503

Insider Information means information that is both material and nonpublic (as explained in section 8). These prohibitions apply even if the transaction in question was planned or initiated before you learned of Insider Information. Note that bona fide gifts of ABTC securities are considered transactions subject to the restrictions in this Policy.

In addition, if in the course of working for the Company you learn of Insider Information about a company with which the Company does business, including a customer or supplier of the Company, you may not trade in that company’s securities until the information becomes public or is no longer material.

Under this Policy, the Company cannot make exceptions even for transactions that may seem necessary or justifiable for personal reasons (such as the need to raise money for an emergency expenditure), or small transactions. Insider trading is transaction-specific, and the securities laws do not recognize any mitigating circumstances.

This Policy applies to your family members who reside with you (including a spouse, a child, a child away at college, stepchildren, grandchildren, parents, stepparents, grandparents, siblings, and in-laws), anyone else who lives in your household, and any family members who do not live in your household but whose transactions in ABTC securities are directed by you or are subject to your influence or control, such as parents or children who consult with you before they trade in ABTC securities (collectively referred to as “Family Members”). You are responsible for the transactions of these other persons and therefore should make them aware of the need to confer with you before they trade in ABTC securities, and you should treat all such transactions for the purposes of this Policy and applicable securities laws as if the transactions were for your own account. For example, if you are talking to your brother-in-law about your job and mention ABTC is going to close its biggest quarter ever, your brother-in-law now has Insider Information and should not trade in ABTC securities. If he does, you will both then be liable for insider trading violations. Therefore, it is your responsibility to inform your brother-in-law of this Policy and the consequences of violation of this Policy.

This Policy does not, however, apply to personal securities transactions of Family Members where the purchase or sale decision is made by a third party not controlled by, influenced by, or related to you or your Family Members. For example, if your mother-in-law has engaged a third-party money manager that independently decides to trade in ABTC securities without talking with you, your mother-in-law, or any ABTC affiliate, then the restrictions in this Policy would not be applicable.

This Policy applies to any entities that you influence or control, including but not limited to any corporations, partnerships, limited liability companies or trusts (collectively referred to as “Controlled Entities”), and transactions by these Controlled Entities should be treated for the purposes of this Policy and applicable securities laws as if they were for your own account.

100 Washington Street, St #100, Reno, NV 89503

You may not trade in the securities of any other company while aware of material, nonpublic information concerning that company if you acquired that information in the course of your Company duties, as the authorities view that as “misappropriating” the material, nonpublic information and therefore may hold you liable for insider trading based on that action.

You may have access to material, non-public information about companies with which the Company does business (e.g., product enhancements, strategic alliances, etc.). This type of information would make you an “insider” of that other company and you must therefore follow the trading restrictions for that other company (which may differ from the Company’s restrictions). Note that information that is not material to the Company may be material to another company, such as a supplier or partner of the Company. When in doubt, contact the Company personnel described in section 5.

Because there is a heightened legal risk, the appearance of improper or inappropriate conduct, or both, in any of the following transactions, you may not engage in any of these:

100 Washington Street, St #100, Reno, NV 89503

When placing an open order with a broker you should inform the broker that you are subject to this Policy and, if applicable, its Trading Window procedures (and Pre-Clearance Procedures, if applicable) to assure that all open orders are canceled prior to the closure of any Trading Window. Exercise caution when placing open orders, such as limit orders or particularly where the order is likely to remain outstanding for an extended period of time, except in accordance with an approved 10b5-1 trading plan (as discussed below). Open orders may result in the execution of a trade at a time when you are aware of Insider Information or otherwise are not permitted to trade in ABTC securities, which may result in inadvertent insider trading violations, Section 16 violations (for officers and directors), violations of this Policy, and unfavorable publicity for you and the Company.

This Policy continues to apply to transactions in ABTC securities even after termination of your service (whether as an employee, consultant or other service provider) to the Company. If you are in possession of Insider Information when your service terminates, you may not trade in ABTC securities until that information has become public or is no longer material. In addition, if the Trading Window is closed or you are subject to a special trading restriction under this Policy at the time you cease to be affiliated with the Company are expected to abide by the applicable trading restrictions until at least the end of the applicable trading restriction.

The Company has established procedures in order to assist in the administration of this Policy, to facilitate compliance with the laws prohibiting insider trading, and to avoid the appearance of any impropriety.

100 Washington Street, St #100, Reno, NV 89503

Persons subject to this Policy may only conduct transactions involving ABTC securities (other than as specified in section 6) when the Company trading window is open. Whether or not the trading window is open, you are always subject to the prohibitions on trading on the basis of Insider Information and any other applicable restrictions in this Policy.

100 Washington Street, St #100, Reno, NV 89503

Designated Insiders may wish to consider entering into pre-arranged 10b5-1 trading plans. 10b5-1 trading plans, when properly adopted, can provide an exception to the general prohibition against trading when the Designated Insider is in possession of material nonpublic information or trading when the trading window is closed. 10b5-1 trading plans provide a defense from insider trading liability if trades occur pursuant to a trading plan that meets certain specified conditions. Under a 10b5-1 trading plan, an insider enters into a binding written plan that specifies the amount, price, and/or date on which securities are to be purchased or sold. The Designated Insider may claim a defense to insider trading liability if the transactions under the trading plan occur at a time when the Designated Insider is in possession of material nonpublic information.

These plans can only be established, modified, or terminated during an open window and at a time when the Designated Insider does not possess material nonpublic information. All such plans of Designated Insiders must be submitted to the GC’s office for review and approval before adoption. All such plans must be executed through a broker and be documented using a form that is pre-approved by the GC’s office. Trading according to an approved 10b5-1 trading plan will not require further preclearance at the time of the trade. You may not enter into more than one (1) 10b5-1 trading plan at the same time. All plans for directors and officers must include a waiting period of the later of (i) ninety (90) days between establishing the plan (or amending the plan) and the first trade made under the plan and (ii) two (2) business days following the filing of the Company’s Form 10-Q or Form 10-K for the quarter in which the plan was adopted or modified, with a maximum one hundred twenty (120) day period. The Company is required to disclose on Form 10-Q and 10-K, as applicable, if a director or officer adopted, materially modified or terminated a 10b5-1 trading plan during the covered period. Actual sales made through 10b5-1 trading plans must be disclosed on a Form 4 for Section 16 Insiders. The details of the rule, and one’s obligations under the rule, are complex, and further information about the rule is available upon request from the GC’s office.

100 Washington Street, St #100, Reno, NV 89503

The quarterly Trading Window closures and event-driven trading restrictions do not apply to those transactions described below. Further, the requirement for pre-clearance, the quarterly Trading Window closures and event-driven trading restrictions do not apply to transactions conducted pursuant to an approved Rule 10b5-1 Plan (although such requirements are applicable to the establishment of the plan itself).

The prohibitions described in this Policy do not apply in the case of the following transactions, except as specifically noted:

100 Washington Street, St #100, Reno, NV 89503

Transactions that involve merely a change in the form in which you own securities are permitted during a period when you are aware of Insider Information or during a company-enforced Trading Window closure. For example, you may transfer shares to an inter vivos trust of which you are the sole beneficiary during your lifetime. Further, transactions in mutual funds that are invested in ABTC securities are not transactions subject to this Policy.

The trading restrictions under this Policy also do not apply to a change in the number of securities held as a result of a stock split or stock dividend applying equally to all securities of a class, or similar transactions.

Federal and state laws prohibit the purchase or sale of securities while aware of Insider Information, or the disclosure of Insider Information to others who then trade in ABTC securities. The SEC, U.S. Attorneys and State authorities vigorously pursue insider trading violations. Punishment for insider trading violations is severe, and could include significant fines and imprisonment. While the regulatory authorities concentrate their efforts on the individuals who trade, or who tip inside information to others who trade, federal securities laws also impose potential liability on companies and other “controlling persons” if they fail to take reasonable steps to prevent insider trading by company personnel. Tipping can result in the same civil and criminal penalties as insider trading, even if the individual who “tipped” did not trade or benefit personally from another’s trading. A violation of law, or even an SEC investigation that does not result in prosecution, can tarnish a person’s reputation and irreparably damage a career.

In addition, your failure to comply with this Policy may subject you to Company-imposed discipline, including termination of your services, whether or not your failure to comply results in a violation of law.

It is your responsibility to help enforce this Policy. You should be alert to possible or unintended violations and promptly report violations or suspected violations (including self-reporting) of this Policy to the GC. If you make an anonymous report, which may also be accomplished in accordance with the procedures set forth in the Company’s whistleblower policy, please provide as much detail as possible, including any evident that you believe may be relevant to the issue.

For purposes of this Policy, the following terms have the meanings indicated below:

100 Washington Street, St #100, Reno, NV 89503

Other employees or officers may also become Designated Insiders as determined by the GC’s office.