Conflicts of Interest Policy

1. Purpose

This policy establishes how the firm identifies, evaluates, discloses, and mitigates actual and potential conflicts of interest in a manner consistent with its fiduciary duties.

2. Scope

The policy applies to all funds, personnel, and affiliates, and to all activities that could give rise to a conflict, including allocation of investment opportunities, expense allocation, co-investments, and related-party transactions.

3. Allocation of Opportunities

Investment opportunities are allocated among the funds according to documented allocation criteria based on each fund’s mandate, available capital, and strategy, applied fairly and without preferential treatment.

4. Expense Allocation

Fund and firm expenses are allocated in accordance with the governing documents and a documented expense-allocation methodology, subject to review by the Chief Compliance Officer and the Limited Partner Advisory Committee.

5. Co-Investments

Co-investment opportunities are offered on a basis that is fair to the funds, with allocation decisions documented and, where required, presented to the Limited Partner Advisory Committee.

6. Related-Party Transactions

Transactions involving the firm, its affiliates, or personnel are subject to review and, where required by the governing documents, approval by the Limited Partner Advisory Committee.

7. Service Providers

The firm selects service providers on the basis of qualifications and value. Any affiliation with a service provider is disclosed and managed under this policy.

8. Disclosure & LPAC Oversight

Material conflicts are disclosed to affected investors and, where applicable, to the independent Limited Partner Advisory Committee, which provides oversight and, where required, consent.

9. Recordkeeping

Identified conflicts and their resolution are documented and retained consistent with the firm’s recordkeeping policy.