Company Policy

1. Introduction

At Sisko Capital, we are committed to maintaining the highest standards of professional conduct, ethical behavior, and regulatory compliance. This Company Policy outlines our core principles and operational guidelines that govern our business practices.

2. Code of Conduct

All employees, contractors, and representatives of Sisko Capital must:

• Act with integrity, honesty, and fairness in all business dealings
• Treat all stakeholders with respect and professionalism
• Avoid any conduct that could damage the firm's reputation
• Comply with all applicable laws, regulations, and internal policies
• Report any suspected violations of this policy or applicable laws immediately

3. Conflict of Interest

Employees must avoid situations where personal interests conflict or appear to conflict with the interests of Sisko Capital or its clients. This includes:

• Outside business activities that compete with or interfere with duties at Sisko Capital
• Financial interests in clients, competitors, or service providers
• Personal relationships that could influence professional judgment
• Accepting gifts, entertainment, or favors that could influence business decisions

All potential conflicts of interest must be disclosed to management immediately for review and appropriate action.

4. Confidentiality and Data Protection

Protecting confidential information is critical to our business. Employees must:

• Safeguard all confidential and proprietary information
• Not disclose confidential information to unauthorized parties
• Use confidential information only for legitimate business purposes
• Comply with all data protection and privacy regulations, including PDPA in Singapore
• Report any suspected data breaches or security incidents immediately

5. Compliance and Regulatory Adherence

Sisko Capital operates under strict regulatory oversight. We are committed to:

• Complying with all applicable securities laws and regulations
• Maintaining appropriate licenses and registrations
• Cooperating fully with regulatory authorities
• Implementing robust compliance monitoring and testing programs
• Providing regular compliance training to all employees

6. Anti-Money Laundering (AML) and Know Your Client (KYC)

We maintain comprehensive AML and KYC procedures to prevent financial crimes. Our policies include:

• Thorough client identification and verification procedures
• Ongoing monitoring of client transactions and activities
• Reporting of suspicious activities to relevant authorities
• Regular training on AML/KYC requirements and red flags
• Maintaining detailed records of all client due diligence

7. Trading and Investment Policies

Our trading and investment activities are governed by strict policies to ensure fair and ethical practices:

• All investment decisions must be in the best interests of our clients
• Trading must be conducted fairly, transparently, and in accordance with applicable regulations
• Market manipulation, insider trading, and other prohibited practices are strictly forbidden
• Best execution practices must be followed for all client transactions
• Appropriate risk management controls must be maintained

8. Personal Trading

Employee personal trading is subject to restrictions to prevent conflicts of interest and insider trading:

• Pre-clearance required for personal securities transactions
• Blackout periods during which personal trading is prohibited
• Restrictions on trading securities on the firm's restricted list
• Prohibition on front-running or trading ahead of client orders
• Regular reporting of personal holdings and transactions

9. Environmental, Social, and Governance (ESG) Considerations

Sisko Capital is committed to incorporating ESG factors into our investment processes. We evaluate potential investments not only on financial metrics but also on their environmental impact, social responsibility, and governance practices. We believe that sustainable and responsible investing contributes to long-term value creation for our clients.

10. Whistleblowing

We encourage employees to report any suspected violations of laws, regulations, or company policies. Sisko Capital maintains a whistleblowing policy that:

• Provides multiple confidential reporting channels
• Protects whistleblowers from retaliation
• Ensures all reports are investigated thoroughly and promptly
• Maintains the confidentiality of whistleblowers to the extent possible

11. Policy Review and Updates

This Company Policy is reviewed and updated regularly to ensure it remains current with evolving laws, regulations, and business practices. All employees are required to acknowledge receipt and understanding of this policy and any updates. Questions regarding this policy should be directed to the Compliance Department.