As a financial services company, Mensch Cologne Capital GmbH ('MCC') is confronted with actual or potential conflicts of interest. Pursuant to Section 63 (2) of the German Securities Trading Act (Wertpapierhandelsgesetz, 'WpHG'), every securities services company must endeavor to avoid conflicts of interest and disclose to its clients the nature and origin of any potential conflicts of interest as well as its policies for dealing with them. Our institution is subject to the supervision of the German Federal Financial Supervisory Authority (BaFin) and the German Central Bank (Deutsche Bundesbank) and is obliged to comply with their regulatory requirements.

We must identify and adequately address actual and potential conflicts of interest. Compliance with applicable laws, regulations and the Principles of Conduct as well as internal processes serves as a starting point in identifying and dealing with potential conflicts of interest. As these may not cover all specific cases, we want to specifically address the issue of potential conflicts of interest and how to deal with them again in this guideline.

This policy covers all employees of Mensch Cologne Capital.

1. Identifying and Addressing Conflicts of Interest:

   As an institution, we must immediately identify and appropriately address conflicts of interest, disclose and prevent business practices that could present conflicts of interest between the interests of Mensch Cologne Capital, its customers and employees. Each employee must always be vigilant and alert to potential conflicts of interest. Our actions toward our clients, the public, our service partners, competitors and the company must always be fair.

2. Reporting Conflicts of Interest:

   Conflicts of interest not covered by pre-existing policies must be reported immediately to the supervisor, appropriate compliance officer or senior management.

3. Periodic Review:

   Each business unit must review its business activities for potential conflicts of interest once a year.

There is no clear definition that covers all potential conflicts of interest that may arise. Even standard market business practices can lead to conflicts of interest. Sometimes activities that seem unremarkable can lead to conflicts of interest that jeopardize the reputation of Mensch Cologne Capital. Conflicts of interest can arise in a variety of ways, but if promptly identified and reported, we can correct and resolve them.

Although it is not practical to provide a sufficiently exhaustive list of all possible conflicts of interest here, we must be ever vigilant to identify them as early as possible. We will consider the following illustrative categories here:

• Conflicts of interest between customers and the institute

• Between different customers

• Conflicts of interest between customers and the institute

1. Conflicts of interest between customers and the company

   These can arise, for example, in the following situations:

   • Access and use of customer information

   • Execution of multiple roles in relation to a customer and/or a transaction

   • Acting in one business area can affect another customer

   • Recommendation of products for which Mensch Cologne Capital may receive higher fees than for others

   • Recommendation of products that are not suitable for the customer

2. Conflicts of interest between different customers

   Can arise, for example, in the following situations:

   • When customers request preferential treatment or compete for certain transactions

   • Customers trade opposite positions

   • If customers invested in the same investment strategy pay different fees

3. Conflicts of interest in relation to employees

   Each of us is required to refrain from investments, activities, interests or relationships, inside or outside the company, that adversely affect our judgment or responsibility with respect to the company and our customers.

   In particular, the following situations should especially alarm employees:

   • Business opportunities that arise from our position as employees of the company or from the use of company property, as well as those that arise from the use of company information

   • Compensation arrangements or incentives provided to human Cologne Capital or employees that influence whether a particular product is recommended to a customer

   • Private investments and business activities that may give rise to conflicts of interest

   • Acceptance of benefits by persons or organizations that have business relationships with Mensch Cologne Capital and that result from the position as an employee at Mensch Cologne Capital, insofar as these are not made available to an extended group of persons (e.g., employee benefits in a canteen)

To avoid conflicts of interest, MCC has committed itself and its employees to high ethical standards. In addition, MCC employees are required to exercise diligence at all times, to observe the principles of lawful and professional conduct as well as market standards, and in particular to attach the greatest importance to the consideration of the customer's interest. We monitor these standards on an ongoing basis as part of control processes.

MCC has conducted a comprehensive analysis to identify differences of interest that could be detrimental to its customers and itself, and to manage them through extensive organizational and behavioral measures. In order to maintain integrity and quality, MCC has a compliance office under the direct responsibility of management, which is charged with identifying, preventing, monitoring and managing conflicts of interest.

• Creation of organizational procedures and implementation of control processes to safeguard customer interests in investment advice, investment brokerage and financial portfolio management

• Disclosure of the costs and incidental expenses associated with our investment services and the financial instruments so that the total costs and their impact on the return on the investment can be seen

• Implementation of an appropriate remuneration system

• Maintenance of insider and blacklists, which serve to monitor the sensitive volume of information and to prevent the misuse of insider information

• Regulation of private transactions of employees as well as monitoring of securities transactions of such employees for whom conflicts of interest may arise in the course of their work

• Regular training of employees

Mensch Cologne Capital's core business is that of a financial portfolio management company. For this reason, we would like to take a separate look here at special mechanisms for avoiding conflicts of interest and ensuring equality of interests in the area of portfolio management:

• Essay as an independent investment boutique. Mensch Cologne Capital is committed exclusively to its clients

• Long-term investment approach

• Corporate philosophy as principle-based meritocracy of ideas

• Firm's success in portfolio management is linked to client success through fee structure

• Transparent fee structure in the respective fund products

• Performance-related remuneration of the company

• Retention of the performance-related payment in the respective fund in the banking book to further ensure alignment of interests. Mensch Cologne Capital receives the same market risk profile as the customers

All potential conflicts of interest that arise are reported and documented in a database, analyzed and their resolution recorded therein.