Conflicts of Interest & Securities Ownership Policy

MCH research conclusions must not be altered to improve the apparent attractiveness of an existing position.

MCH may permit directors, employees, analysts, affiliates or associated investment vehicles to hold securities discussed in MCH Publications, subject to applicable law and internal controls.

Material holdings and conflicts are disclosed where appropriate.

Security-level research pages carry a standard disclosure field headed MCH Interests. The field takes one of the following controlled values:

• "No material financial interest disclosed at publication cut-off."
• "MCH-related persons and/or associated investment vehicles may hold a financial interest in securities discussed. See Conflicts Policy."
• a more specific disclosure, where required

The value shown is drawn from disclosure data maintained per security or report. MCH does not present a statement of no interest unless that is what the disclosure data records at the publication cut-off of the report.

MCH requires:

• version control over methodology
• documentation of material methodology changes
• no retrospective model changes solely to favour an existing holding
• separation of research methodology governance from portfolio-position preferences
• disclosure of material issuer relationships, where applicable
• disclosure of compensation arrangements, where relevant
• policies concerning personal-account dealing, when required

This policy applies to any investment vehicle or fund that MCH or its affiliates may establish. Where such a vehicle holds a financial interest in a security discussed in MCH Publications, that interest is disclosed through the MCH Interests field, and research methodology governance remains separate from the vehicle's portfolio positions.

Methodology versioning and the documentation of material changes are described in the Research Integrity Policy. Material changes to published conclusions are handled under the Research Corrections & Amendments Policy. The nature of the research itself is described in the Investment Research & Regulatory Disclaimer.

Questions about this policy or about a specific disclosure may be sent to research@mchadvisoryservices.com.