Code of Conduct for Capito Capital Management A/S

1. Introduction

Capito Capital Management (“Capito”) is committed to upholding the highest integrity, professionalism, and compliance standards in all its business activities. This Code of Conduct sets forth the principles and expectations that guide our employees, partners, and representatives in their professional conduct. Compliance with this Code is mandatory for all employees and associates.

2. Core Principles

2.1 Integrity and Ethics

• All employees must act honestly, transparently, and ethically in all dealings with investors, partners, and colleagues.

• Capito does not provide investment advice but ensures that all offered opportunities are presented accurately and fairly.

• Employees must avoid any misleading or exaggerated statements when discussing investment opportunities.

• Conflicts of interest must be disclosed and appropriately managed.

2.2 Compliance with Laws and Regulations

• Capito fully complies with applicable laws, including financial regulations and anti-money laundering (AML) policies.

• Employees must adhere to internal compliance policies and procedures to ensure legal and regulatory compliance.

• Training on relevant regulations will be conducted regularly to ensure that all employees understand their obligations.

• Any breaches of regulatory requirements must be reported immediately to the management team.

• Capito has strict AML procedures in place to prevent money laundering and terrorist financing. Employees must:

1. 1. Conduct thorough due diligence on all investors and partners before engaging in business transactions.
   2. Report any suspicious activity to the designated AML compliance officer.
   3. Follow Know Your Customer (KYC) protocols to verify the identity of all investors and partners.
   4. Ensure that all financial transactions comply with AML laws and internal policies.

2.3 Confidentiality and Data Protection

• All non-public information regarding investors, partners, and internal operations must be treated as confidential.

• Employees must follow data protection laws and internal policies to safeguard sensitive information.

• Unauthorized sharing of confidential information is strictly prohibited and may lead to disciplinary actions.

3.1 Investor Relations and Communication

• Employees are strictly prohibited from providing tax or investment advice. All communications with investors must be limited to presenting investment opportunities factually and transparently, without making personalized recommendations.

• Investors are approached through invitation-only events and direct engagement, ensuring that Capito’s offerings remain exclusive and targeted.

• Communications with investors must be professional, clear, and free of misleading statements.

• Employees must always present information factually and avoid making guarantees or unverified claims about investment returns.

• All sales and marketing materials must be reviewed and approved by the compliance team before distribution.

• Employees should never pressure investors into making decisions but instead provide them with sufficient information to make informed choices.

3.2 Workplace Behavior

• Employees must treat each other with respect and foster an inclusive and professional work environment.

• Discrimination, harassment, or any form of misconduct will not be tolerated.

• Professionalism must be maintained in all internal and external interactions.

3.3 Conflicts of Interest

• Employees must avoid situations where personal interests conflict with Capito’s business activities.

• Any potential conflicts must be reported to management and handled transparently.

• Employees may not accept gifts, entertainment, or favors that could compromise their professional judgment.

3.4 Social Media Policy

• Employees may not disclose sensitive information or make speculative statements about investments on social media or in public forums.

4. Ensuring Compliance Across the Organization

• Capito implements rigorous internal compliance measures to ensure adherence to all regulatory requirements.
• Regular audits and compliance checks will be conducted to verify that all employees operate within legal boundaries.
• Employees must participate in compliance training sessions and stay informed about changes in relevant laws and policies.
• Any suspected unethical behavior, regulatory violations, or legal breaches must be reported immediately to the compliance officer or management team.
• Capito requires that all investors be qualified as either semi-professional or professional investors before engaging in any investment opportunities. Employees must

1. 1. Conduct appropriate assessments to verify investor status in accordance with regulatory requirements.

   2. Maintain documentation proving the investor’s qualification status.

   3. Ensure that no investment opportunities are offered to retail investors.

   4. Report any uncertainties or issues regarding investor qualification to the compliance team.

   5. Ensure that all investors have received and acknowledged Capito’s official disclaimer before proceeding with any investment opportunity.

5. TransparencyandAccountability

• Employees are responsible for maintaining accurate records and ensuring transparency in financial transactions.

• Any irregularities in financial reporting must be escalated to the appropriate authorities within the company.

Employees who fail to comply with this Code or any applicable regulations will be subject to disciplinary action, including termination of employment or legal consequences if necessary.

6. Compliance and Enforcement

• Violations of this Code may result in disciplinary actions, including termination of employment or partnership agreements.
• Capito reserves the right to update this Code as needed to align with evolving business and regulatory standards.
• All employees and partners must acknowledge their understanding and commitment to this Code of Conduct upon joining Capito and reaffirm their compliance annually.

7. Whistleblower Protection

• Employees who report violations of this Code of Conduct or regulatory breaches in good faith will be protected from retaliation.

8. ESG Commitment

• Capito is committed to responsible investing, integrating ESG principles into our decision-making process.

9. Consequences of Violations

• Violations of this Code of Conduct will be addressed in accordance with the severity of the offense and may result in verbal or written warnings, suspension, or termination of employment.

10. Acknowledgment

All employees and partners must acknowledge that they have read, understood, and will comply with this Code of Conduct. Compliance is essential for maintaining Capito’s reputation, legal standing, and commitment to ethical business practices.
Version CF01.04.2025