Conflict of Interest Policy.

1.     Purpose

Lamal Partners Limited is committed to conducting its business transparently and with the highest ethical standards. This Conflict-of-Interest Policy outlines our approach to identifying, disclosing, and managing actual, potential, or perceived conflicts of interest to maintain trust with our clients, partners, and stakeholders.

2.     Scope

This policy applies to all Directors, employees, contractors, consultants, and any individuals engaged on behalf of Lamal Partners Limited.

3.     Definition

A conflict of interest arises when personal, financial, or other interests may compromise—or appear to compromise—an individual’s impartiality or the company’s obligations.

Examples include but are not limited to:

• Acting on both sides of a transaction without disclosure

• Holding undisclosed financial interests in clients or suppliers

• Personal relationships influencing business decisions

• Competing priorities between Lamal mandates

4.     Policy Statement

• All conflicts, whether actual or potential, must be promptly disclosed to the Chief Compliance Officer (CCO) or an appropriate Director as outlined in the Policies & Procedures Manual.

• Directors must disclose conflicts to the Board and recuse themselves from related decisions.

• Where conflicts are identified, appropriate safeguards will be implemented, such as information barriers (“Chinese walls”), reallocation of responsibilities, or obtaining informed consent from affected parties.

• Failure to disclose conflicts may result in disciplinary action, up to and including termination.

5.     Procedures

• Disclosure obligations are included in onboarding and reinforced via regular training.

• A Conflict of Interest Register is maintained by the Head of Administration or CCO, documenting all disclosures and mitigation actions.

• Periodic reviews of conflicts and mitigations are undertaken to ensure ongoing compliance.

On behalf of the board of directors,

Lamal Partners Limited.