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OMNES CAPITAL the Code of Ethics, and the Conflicts of Interest policy. The AML-CTF framework governs the firm%u2019s approach to money laundering and terrorist financing risk across fundraising, investments, and disposals; it includes TracFin reporting obligations, employee awareness measures, and a specific anti-corruption component.Risk Assessment ApproachOmnes maintains two distinct risk maps, updated on an ongoing basis. The first covers the management company itself: it is added to as second-level controls are conducted, distinguishing between gross risk (before controls) and net risk (after the application of the control framework). Weightings are reviewed annually and new regulatory requirements trigger updates to the relevant risk categories. The second risk map covers the fund portfolio, providing an analysis of risks at portfolio level, including market and interest rate risks, as well as more specific political and lifecycle risks where relevant. Sustainability risk, cybersecurity, and governance are integrated into both maps, reflecting their cross-cutting nature within the firm%u2019s overall risk profile. A Sustainability Risk policy is publicly available on the Omnes website and the definitions and principles set out therein are actively applied in practice.Gifts, Conflicts of Interest, and Personal ConductThe Code of Ethics establishes clear rules governing gifts and hospitality, personal investments, and external activities. For gifts, a threshold applies above which employees must inform their line manager and seek authorization before acceptance to prevent conflicts of interest. Invitations are subject to declaration, regardless of monetary value. Employees are also prohibited from investing in portfolio companies or entities with which Omnes has a formal partnership; however, outside this restricted list, personal investment in listed securities is permitted. Any external mandate, function, or directorship must be declared to the compliance function and receive prior approval from the CEO.These rules are subject to an annual verification process: all employees are required to submit a personal declaration that covers investments held, mandates exercised, and gifts received during the year. Approximately 20% of declarations are then selected for documentary verification (such as review of brokerage account statements). This systematic, riskbased approach to personal conduct controls provides Omnes with oversight of employee behavior in areas most susceptible to conflicts of interest.3. SUSTAINABILITY IN OUR OPERATIONS