These principles of conduct are an expression of Mensch Cologne Capital GmbH's commitment to integrity and the highest ethical standards. They define the standards within the company and serve as a behavioral guideline for all employees and decision makers of Mensch Cologne Capital. They help us to make the right decisions when performing our work. Every employee is responsible for internalizing and following these behavioral guidelines. They form the basis of the corporate culture of Mensch Cologne Capital GmbH.

As a financial services company, Mensch Cologne Capital GmbH considers itself committed to its customers and puts their interests first. To this end, we are committed to fostering a culture based on the following two core values:

• Common sense in a traditional value system of right and wrong

• A corporate philosophy as a principle-based meritocracy of ideas

Living these values means, above all, conducting ourselves and our business in accordance with applicable law, competent regulation and company rules.

Mensch Cologne Capital GmbH sees itself as a principle-based meritocracy of ideas. That is, as a system that brings together smart independent thinkers in constructive disagreement. With the goal of fostering the best collective thinking to resolve disagreements in a credibility-weighted way. We believe that meaningful work and relationships are created by assembling high performing teams and incentivizing them to rigorously, constantly, and thoughtfully challenge each other.

To ensure this, the overriding principles of Mensch Cologne Capital are as follows:

• Radical open-mindedness

• Radical truth and radical transparency

Radical open-mindedness: The motivation for radical open-mindedness lies in the honest concern that we may not be able to see all possibilities optimally. It is the ability to effectively explore different points of view and possibilities without being distracted by one's own ego. It requires giving up the pursuit of being right and replacing it with the will to find the truth. Radical open-mindedness allows us to consider all good choices and make the best possible decisions.

Radical truth and radical transparency: Understanding what is true is an essential prerequisite for success. Being radically transparent in all respects, especially about mistakes and weaknesses, creates an environment of understanding that leads to improvement. Being radically open and transparent with others, and expecting it in return, ensures that important issues surface. It enforces good behavior and good thinking, as everyone has to explain themselves and thus everyone can openly see the merits of each logic. Radical truth and radical transparency help maintain high standards because it is clear who does things well and who does things poorly. Thus, radical truth and transparency are fundamental in a true meritocracy of ideas.

Putting the customer's interest first: The principle requires us to put the customer's needs first and avoid potential conflicts of interest between them and us. This is addressed in detail in the company policy on avoiding Conflict of Interest. Every employee must always be alert to whether his or her actions could potentially trigger a conflict of interest.

Common sense: Applying good judgment based on the traditional value system of right and wrong. All employees are required to make ethical and informed decisions and to take responsibility for their actions. All employees are required at all times to ask themselves whether their actions comply with applicable laws and regulations.

Mensch Cologne Capital GmbH's reputation for integrity and excellence is essential to the success of the company. Potential risks arise when a transaction, business practice, customer or counterparty could damage the reputation of the company. For example:

• A customer is associated with corruption, money launderers or other unlawful activities

• A transaction lacks reasonable economic necessity or business background

• A transaction raises significant environmental or social risk issues

• A transaction raises significant concerns about suitability for the client or tax issues

• A transaction entails the risk of becoming embroiled in a conflict of interest

Every employee is encouraged to openly express possible ethical and legal concerns. This is part of our meritocracy of ideas. The employee does not have to fear any negative consequences for this.

Mensch Cologne Capital GmbH aims to meet the highest ethical standards of conduct. Our commitment to follow ethical behavioral guidelines means that we comply with applicable law and the relevant regulation. Together with our corporate philosophy and core values, this forms the foundation of our culture and actions.

Conduct risk arises from the behavior of company employees. It can arise in connection with business activities, but also from other behaviors that can harm the company. Conduct may result in disciplinary action.

Each of us is required to adhere to the highest standards of ethical behavior, to refrain from activities that could damage the reputation of the company or its customers, to be aware of the potential consequences such behavior could have for our customers, the markets and the company. Furthermore, we are required to identify and report potential conduct risks.

Mensch Cologne Capital is committed to free, fair and competitive markets. The law prohibits market abuse, including manipulative trading activities.

Mensch Cologne Capital's business is structured to ensure that you use our employees, facilities, products and services only for lawful purposes. We are committed to full compliance with all applicable anti-money laundering and anti-terrorist financing laws, rules and regulations. Mensch Cologne Capital employees must not engage in or facilitate money laundering. Doing so may result in civil as well as criminal penalties for both the employee and the company.

Mensch Cologne Capital GmbH maintains accurate and complete books and records relating to our business activities that satisfy legal requirements. The financial information in our books is complete and accurate in all material respects.

In the course of litigation, internal investigations or governmental, regulatory or administrative investigations, reviews or audits involving Mensch Cologne Capital, the company may request employees to provide information. Each employee is expected to be open and cooperative and to provide truthful, accurate and complete information in connection with such a request.

Mensch Cologne Capital GmbH is open, cooperative and constructive with our regulators.

Mensch Cologne Capital is an equal opportunity employer. Employment with MCC is based on merit, competence and qualifications and is not influenced in any way by race, color, religion, sex, national origin/ethnicity, veteran status, disability status, age sexual orientation, gender identity, marital status, mental or physical disability, or any other status protected by law.

Mensch Cologne Capital is committed to conducting business in an environmentally and socially responsible manner. We consider environmental, social and governance (ESG) factors in our business activities as we create long-term value for our customers.

Confidential information is information that we create, develop, receive, use, learn about or have access to as a result of our employment with Mensch Cologne Capital that is not generally known to the public and is so sensitive that loss or unauthorized disclosure or access could result in legal, business, regulatory or reputational harm to our customers or Mensch Cologne Capital.

Each employee must protect all confidential information, regardless of its form or format. In particular, an employee may only access confidential information that he or she needs and is authorized to see. We may disclose confidential information only to company employees and agents who have a legitimate business reason to know it, and we must take reasonable steps to prevent unauthorized persons from obtaining such confidential information.

All business communication should convey information clearly, concisely and professionally. Careless communication that fails to meet these standards can have serious consequences.

Employees may use Mensch Cologne Capital's systems only for company business and limited and appropriate personal use. Company systems are broadly defined as any technology owned or accessed by the company, including communications systems.

All information stored in or transmitted through the use of the company's systems is the property of Mensch Cologne Capital. By using or accessing company systems, the employee agrees that the company will monitor, access, review, disclose, intercept, and record their use of and access to company systems and all data moving through and/or stored on company systems. As an employee, you must not take any steps to interfere with the company's ability to monitor, access, review, disclose, intercept or record such information. Mensch Cologne Capital records voice communications when required by law or when there is a demonstrated business need to do so. Employees should not use the company's systems for personal use unless you wish your personal use and communications to be monitored.

We are all collectively responsible for protecting the company from cyber threats. I.e., actions, circumstances or events that have the potential to maliciously exploit technology-based vulnerabilities that may result in damage or compromise to the confidentiality, integrity or availability of company information, systems and/or networks.