Conflicts Policy

Approved by the Sole Administrator on 8 June 2026 · Version 1.0

PREAMBLE

European Equity Research Partners, S.L. (hereinafter, «EERP» or the «Company») is fully aware that the operating model of issuer-sponsored research rests upon a structural tension: the issuer analysed pays for the research whose economic and reputational function consists, precisely, in informing the investor on criteria of objectivity and independence that are immune to the interest of the paying issuer. The rigorous, transparent and verifiable management of this tension is the condition of viability of the model and the condition of credibility of EERP before investors, distributing investment firms, supervisory authorities and the market in general.

This Conflicts of Interest Policy (hereinafter, the «Policy») constitutes the dedicated, operational and exhaustive development of the conflicts of interest regime established in Title V of the EERP Code of Conduct (hereinafter, the «Code»).

The Policy is approved in compliance with:

The Policy is hierarchically subordinate to the Code and develops in detail its Title V (Articles 27 to 31). In the event of apparent contradiction, the Code prevails. The Policy does not replace the Code in any matter; it deepens it in the specific matter of conflicts of interest.

EERP declares that this Policy is a living instrument. Its effectiveness is not measured by its formal existence but by its substantive application: effective identification of conflicts, effective management when they materialise, and effective disclosure to the reader of the research and to interested third parties. The mandatory annual review under Title IX and the annual reporting by the Compliance Officer to the management body are the institutional guarantees of this effectiveness.

TITLE I. GENERAL PROVISIONS

Article 1. Object and purpose of the Policy

1.1. The purpose of the Policy is to develop in detail, in accordance with Article 28 of the Articles of Association and Title V of the Code, the regime for the identification, prevention, management and disclosure of the conflicts of interest inherent in the activity of EERP.

1.2. The Policy seeks to:

Article 2. Applicable regulatory framework

2.1. The Policy is governed by the following regulatory framework, cited without prejudice to any other applicable provision:

2.2. In the event of conflict between rules, the rule of higher rank shall prevail and, failing that, the more demanding rule from the standpoint of investor protection and market integrity.

Article 3. Specific definitions

3.1. For the purposes of this Policy, the definitions of Article 3 of the Code apply. In addition, the Policy incorporates the following specific definitions:

Article 4. Scope of application (persons)

4.1. The Policy binds all Subject Persons in accordance with Article 4 of the Code, without exception.

4.2. The obligations of declaration, prevention, management and disclosure imposed by the Policy extend, to the extent applicable to them and in accordance with Article 4.3 of the Code, to the Connected Persons of the Subject Persons, on the terms of Article 17 of this Policy.

4.3. Where a Subject Person is a legal entity (in particular the domestic and foreign holding companies through which certain Partners hold an interest in the capital of EERP), the obligations of the Policy are governed by the specific regime of Article 4.2 of the Code, falling in civil-patrimonial terms upon the legal entity and, in their specific role, upon the natural persons who act on its behalf to the extent that directly applicable European regulations impose it personally.

Article 5. Scope of application (subject matter)

5.1. The Policy applies to all activity of EERP that may give rise to conflicts of interest, and in particular to:

Article 6. Binding character and publicity

6.1. The Policy is binding on all Subject Persons from its entry into force.

6.2. The Policy is published on the corporate website of EERP in a version accessible to the public, in accordance with Article 28 of the Articles of Association and Clause 1 of the EU Code. The published version is kept up to date at all times.

6.3. Express reference to the Policy is included:

6.4. Material amendments to the Policy are published simultaneously with their approval, indicating the date of entry into force, in accordance with Title IX.

TITLE II. PRINCIPLES FOR THE MANAGEMENT OF CONFLICTS OF INTEREST

Article 7. Specific governing principles

The management of conflicts of interest at EERP is governed by the following specific principles, which complement the general principles of Title II of the Code:

7.1. Principle of substantive editorial independence. EERP guarantees that no analytical decision (recommendation, target price, content of the analysis, timing of publication) is affected by commercial considerations, by the interests of the paying issuer, by the interests of the Partners, by the interests of the Allied Exchanges, or by the interests of the distributing investment firms. Independence is measured not only formally but substantively: each decision must be defensible before an Informed Observer.

7.2. Principle of primacy of the interest of the addressee investor. Where the interests of the various parties connected to the activity of EERP come into tension, the interest of the investor to whom the research is addressed in receiving an objective, complete and comprehensible analysis that enables him to form his own judgement shall prevail.

7.3. Principle of active transparency. EERP discloses the circumstances required by the applicable regulations and may disclose, where it considers it appropriate, others that are relevant for assessing the objectivity of the analysis.

7.4. Principle of proportionality. The prevention and management measures adopted are proportionate to the nature, severity and likelihood of the conflict. Minor conflicts may be managed by disclosure; material conflicts may require the exclusion of the affected Partner, rotation of the Analyst or waiver of coverage.

7.5. Precautionary principle. Where there is doubt as to whether a situation constitutes a relevant conflict, EERP assumes that it does and applies the corresponding measures. The burden of proving that there is no conflict falls on the person maintaining that position, not on the person raising the doubt.

7.6. Principle of complete documentation. All decisions concerning the identification, classification, prevention, management and disclosure of conflicts are documented in the Conflicts Register, with express reasoning, date, responsible person and traceability. Documentation is the guarantee of auditability by third parties.

7.7. Principle of continuous and non-episodic management. Conflicts are not managed «once and for all». The Compliance Officer reviews the catalogue and the Register on a continuous basis, and the Internal Review Committee meets with whatever frequency is necessary to maintain active vigilance.

7.8. Principle of extension to Connected Persons. The conflicts regime is not limited to Subject Persons in the strict sense: it reaches their Connected Persons on the terms of Article 17 and in accordance with the broad definition of Article 3(n) of the Code. Circumvention through Connected Persons itself constitutes a breach.

Article 8. Hierarchy of solutions for conflicts

8.1. Where a potential or actual conflict of interest is identified, EERP applies the following hierarchy of solutions, in order of preference:

8.2. Disclosure can never replace prevention or management. That is: if a conflict can be effectively prevented or managed, it is not sufficient to disclose it; it must be prevented or managed in addition to being disclosed.

8.3. The decision as to which level of the hierarchy applies rests with the Compliance Officer, with the support of the Internal Review Committee where appropriate and, in cases of recusal of the Compliance Officer, with the external Compliance Adviser in accordance with Article 9.4 of the Code.

TITLE III. IDENTIFICATION OF CONFLICTS OF INTEREST

EERP maintains a closed and categorised Conflicts Catalogue, organised into the following categories. The enumeration within each category is not exhaustive: it identifies the typical types but the Compliance Officer may incorporate others that are identified in operations.

Article 9. Firm-level conflicts

9.1. Firm-level conflicts are those arising from the overall position of EERP as an entity, its joint contractual relationships and its business model. They comprise:

Article 10. Conflicts at the level of Partners and natural persons who control the holding companies

10.1. Partner-level conflicts are those arising from the personal or corporate position of the Partners of EERP (or of the natural persons who control the partner holding companies in the cases where this applies) in relation to the activity of the firm. They comprise:

Article 11. Conflicts at the level of the Sole Administrator

11.1. The Sole Administrator of EERP simultaneously performs the corporate function of administration, the function of internal Compliance Officer (in accordance with Article 9 of the Code) and, where applicable, the status of Partner of the firm. This concentration of functions requires specific attention to the following aspects:

11.2. The recusal regime entails that the Sole Administrator, where he identifies a conflict in himself, refers the matter to the external Compliance Adviser, who assumes the function of ad hoc Compliance Officer for that matter, in accordance with Article 10 of the Code and Article 29 of this Policy. The recusal is expressly documented in the Conflicts Register, indicating: the nature of the conflict, the date of identification, the final decision adopted by the external Adviser and the reasoning.

Article 11 bis. Specific articulation regime where the Sole Administrator and the Compliance Officer coincide in the same natural person

11 bis.1. This Policy has been drafted with a view to permanence and under the general principle of functional separation between the Sole Administrator and the internal Compliance Officer. The obligations of reporting, escalation, review, communication or information that the Policy provides for between the one and the other presuppose, as a general rule, that both functions are held by different natural persons, which constitutes the governance architecture with the greatest guarantee of independent control and, therefore, the institutionally preferable option where the operational and governance circumstances of the Company so advise.

11 bis.2. Notwithstanding the foregoing, the Policy expressly recognises that, at the time of its initial approval and during the period in which the General Meeting of Partners has not resolved upon the separation, both functions are held by the same natural person, in accordance with Article 9 of the Code. In this case, the provisions of Article 9 bis of the Code apply on a preferential and substitutive basis with respect to the reciprocal obligations between the Sole Administrator and the Compliance Officer established in this Policy.

11 bis.3. In particular, in the scenario of concentration of functions referred to in the preceding paragraph:

11 bis.4. At the moment when the General Meeting of Partners or the competent body resolves upon the separation of the functions by appointing a professional Compliance Officer distinct from the Sole Administrator, the general provisions of this Policy on reciprocal obligations between the two functions shall apply fully and without need for any additional regulatory amendment. The separation is documented with reasoning and published simultaneously on the corporate website, indicating the effective date.

11 bis.5. The rule of this article is interpreted without prejudice to the full application of the recusal regime of Article 9.4 of the Code and of Article 29 of this Policy where, in any governance scenario, the Compliance Officer has a personal or family conflict in a matter submitted to his decision.

Article 12. Conflicts at the level of the Head of Research

12.1. The Head of Research, in his structural function in accordance with Title III of the Code, may give rise to specific conflicts:

Article 13. Conflicts at the level of External Analysts

13.1. The External Analysts engaged may give rise to specific conflicts arising from their nature as commercial professionals who maintain parallel activities. They comprise:

Article 14. Conflicts at the level of the issuer client

14.1. Issuer clients may give rise to specific conflicts arising from their business position. They comprise:

Article 15. Conflicts at the level of distributing investment firms

15.1. The investment firms that distribute EERP's research to their clients may give rise to specific conflicts:

Article 16. Conflicts at the level of Allied Exchanges

16.1. The Allied Exchanges (stock exchanges, organised markets or other market infrastructures with which EERP has entered into a white-label licence agreement or strategic alliance) give rise to specific structural conflicts, in accordance with Title XI of the Code:

Article 17. Conflicts arising from Connected Persons

17.1. The Connected Persons of the Subject Persons, in accordance with the broad definition of Article 3(n) of the Code, may give rise to specific conflicts by extension, especially where they:

17.2. Each Subject Person is responsible for ensuring that his Connected Persons do not act in contravention of the regime of this Policy, in accordance with Article 4.3 of the Code. This responsibility includes:

17.3. The definition of Connected Person in Article 3(n) of the Code is interpreted with an expansive intent, in line with the purpose of the regime of avoiding circumvention through persons or entities close to the Subject Persons. Where there are reasonable indications that a natural or legal person may have the status of Connected Person in respect of a Subject Person, the Compliance Officer applies the corresponding regime on a precautionary basis and opens a file to clarify the classification, in which the parties involved may submit the evidence and information they consider relevant. In cases of reasonable doubt that cannot be resolved with the available information, the Compliance Officer provisionally resolves in favour of classification as a Connected Person and applies the corresponding measures, without prejudice to the right to review the classification if supervening evidence is submitted that justifies the modification. The provisional resolution is documented with reasoning in the Conflicts Register.

TITLE IV. PREVENTION OF CONFLICTS OF INTEREST

Article 18. Organisational measures

18.1. EERP maintains the following structural organisational measures to prevent conflicts of interest:

Article 19. Information barriers

19.1. EERP maintains effective information barriers in accordance with Title VI of the Code:

Article 20. Declaration regime of the Subject Persons

20.1. Each Subject Person submits to the Compliance Officer the following declarations:

20.2. The declarations are submitted on the forms approved by the Compliance Officer. They are kept in the Conflicts Register by the Compliance Officer throughout the term of the Subject Person's connection with EERP and for a subsequent period of 5 years.

20.3. The declarations are truthful, complete and timely. Wilful omission or material inaccuracy constitutes a very serious breach in accordance with Title XIV of the Code.

Article 21. Personal account dealing regime

21.1. The Subject Persons and their Connected Persons are subject to the regime of Title IX of the Code, which prohibits personal transactions in Covered Securities on terms that contravene that Title.

21.2. The Compliance Officer keeps the Restricted List up to date and communicates it in a timely manner to the Subject Persons so that they know at all times which Securities are affected.

21.3. Requests for prior authorisation for transactions permitted subject to authorisation (Article 55 of the Code) are channelled on the form approved by the Compliance Officer and are decided by the Compliance Officer within a reasonable period.

21.4. The specifically reinforced regime of the Head of Research (Article 53.3 of the Code) entails that all Covered Securities are subject to the Restricted List regime for him and his Connected Persons at all times.

Article 22. Regime of parallel activities of the Partners

22.1. The Partners (and, where applicable, the natural persons who control the partner holding companies) comply with the regime of Title VIII of the Code (Articles 47 to 50). The Compliance Officer maintains an up-to-date map of parallel activities, accessible to the external Compliance Adviser and, to the extent necessary, to the Head of Research and to the management body.

22.2. Where a parallel activity gives rise or may give rise to a crossover with an issuer covered or potentially covered by EERP, the management procedure of Article 28 of this Policy applies.

22.3. The Partner who is Head of Research is additionally subject to the regime of total exclusion from the commercial function of Article 51 of the Code.

Article 23. Validation of External Analysts before the allocation of coverage

23.1. Before assigning to an External Analyst the coverage of a specific issuer, the Head of Research, with verification by the Compliance Officer, checks:

23.2. If manageable conflicts are identified, they are documented in the Conflicts Register and the corresponding management measures are applied (reinforced disclosure, double editorial review, etc.).

23.3. If unmanageable conflicts are identified, coverage is not assigned to that External Analyst and an alternative is sought.

Article 24. Verification of issuers before signing the contract

24.1. Before signing an issuer-sponsored research contract with an issuer, EERP carries out, under the coordination of the Compliance Officer, the following verifications:

24.2. Signing the contract without having completed the verification constitutes a breach of the internal regime on the part of the commercial officer responsible.

TITLE V. MANAGEMENT OF CONFLICTS THAT MATERIALISE

Article 25. Notification to the Compliance Officer

25.1. Any Subject Person who identifies a potential or actual conflict of interest, whether their own or another's, notifies it to the Compliance Officer without undue delay from the moment of its identification.

25.2. The notification is made in writing (including by email) and indicates:

25.3. If the notifier prefers to use the internal whistleblowing channel for reasons of confidentiality or fear of reprisals, he may do so in accordance with Article 76 of the Code. In that case the guarantees of Law 2/2023 apply in accordance with the voluntary assumption that EERP has made.

25.4. If the conflict affects the Compliance Officer himself, the recusal regime of Article 9.4 of the Code and Article 29 of this Policy applies. The notification is channelled directly to the external Adviser.

Article 26. Analysis of the conflict by the Compliance Officer

26.1. Upon receipt of a notification of conflict, the Compliance Officer opens an analysis file without undue delay from receipt.

26.2. The analysis file comprises:

26.3. For material conflicts or those of significant complexity, the Compliance Officer refers the file to the Internal Review Committee for decision. For minor conflicts, the Compliance Officer may decide directly and refer the matter to the Committee solely for its information and incorporation into the quarterly reporting.

Article 27. Decision of the Internal Review Committee: catalogue of measures

27.1. The Internal Review Committee, when considering the file of a material conflict, may adopt any of the following measures, individually or in combination, according to the nature and severity of the conflict:

A. Reinforced prevention measures

B. Management measures

C. Reinforced disclosure measures

D. Extreme measures

27.2. The decision of the Internal Committee is documented with reasoning in the Conflicts Register and, where appropriate, is notified to the affected issuer in accordance with Article 42 of this Policy.

27.3. The decision of the Internal Committee is reviewable by the Sole Administrator or, where applicable, by the General Meeting of Partners where the decision affects matters within its competence under the Articles of Association. The review does not suspend the effectiveness of the measure adopted unless there is an express decision to the contrary.

Article 28. Specific management regime where a Partner's parallel activity crosses over with a covered issuer

28.1. Where a crossover is identified in accordance with Article 50 of the Code, the following procedure applies:

28.2. The obligation to declare crossovers is continuous: it is not exhausted by the initial or annual declaration of Article 20 nor by the declaration of Article 48 of the Code. Any crossover that arises during operations must be declared without undue delay from its identification.

28.3. Failure to comply with the obligation to declare crossovers constitutes a very serious breach in accordance with Title XIV of the Code and may trigger the consequences provided for in the Shareholders' Agreement.

Article 29. Specific regime where the Compliance Officer has a conflict: recusal and referral

29.1. Where the Compliance Officer identifies a direct or indirect conflict of interest in a matter submitted to his decision —arising from his status as Partner, from his family connection to other Partners, or from any other personal circumstance—, he recuses himself on his own motion from his compliance function and refers the matter to the external Compliance Adviser, who assumes the function of ad hoc Compliance Officer for that matter.

29.2. The recusal is documented in the Conflicts Register before the decision is adopted, indicating:

29.3. The Subject Persons affected by a decision of the Compliance Officer may, on reasoned grounds, request the recusal of the Compliance Officer where they consider that a conflict exists. The request is channelled to the Compliance Officer himself and, if he rejects the recusal, to the external Adviser, who decides. The decision of the external Adviser on the recusal is binding.

29.4. The external Adviser, when he assumes the functions of ad hoc Compliance Officer, has the same powers as those of Article 9.2 of the Code in respect of the specific matter, and applies the criteria of this Policy and of the Code.

29.5. Regime applicable where the Compliance Officer and the Sole Administrator coincide in the same natural person. Where the situation of Article 11 bis arises and the natural person who performs both functions identifies a conflict of interest in relation to a matter that simultaneously affects his role as Compliance Officer and his role as Sole Administrator, the following two provisions apply in a coordinated manner:

29.6. In the case of the preceding paragraph, the affected natural person continues to exercise all the corporate functions of Sole Administrator in matters not affected by the conflict, without the specific recusal entailing a general vacancy of the office. The General Meeting of Partners assumes only the corporate decisions specifically affected by the conflict.

29.7. The decisions adopted in accordance with paragraph 29.5(b) are documented in the minutes of the General Meeting and, simultaneously, are transferred to the Conflicts Register in order to guarantee the cross-traceability of the two channels of articulation.

TITLE VI. DISCLOSURE OF CONFLICTS OF INTEREST

Article 30. Mandatory disclosures in each piece of research

30.1. Every piece of research published by EERP that constitutes an investment recommendation, in accordance with Article 21 of the Code, includes the following mandatory disclosures on conflicts of interest:

30.2. The disclosures are included in the body of the piece in a visible and prominent manner. The most relevant disclosures (contractual relationship with the issuer, type of research, identification of the authoring Analyst) are included on the cover and in the executive summary. The remaining disclosures are included in a specific, clearly identified section at the end of the piece.

The final literal wording of the disclosures incorporated into each specific piece is set out in the separate Disclaimers document, approved by the Compliance Officer and periodically reviewed.

Article 31. The 5% threshold regime

31.1. In accordance with Article 3(2)(d) of the Delegated Regulation of the EU Code, where an issuer represents more than 5% of EERP's consolidated gross revenue of the previous year, the following specific regime applies:

31.2. The 5% regime applicable to the External Analyst. Where the revenue of the External Analyst from an issuer (directly or through EERP's coverage of that issuer) represents more than 5% of the External Analyst's consolidated gross revenue of the previous year, equivalent disclosure is applied in accordance with Clause 3(2)(f) of the EU Code. The verification of the threshold is carried out by the Compliance Officer by means of a declaration of the External Analyst at the time of the allocation of coverage and is updated annually.

Article 32. Specific disclosures where the issuer is listed on an Allied Exchange

32.1. Where a piece of research relates to an issuer listed on an Allied Exchange of EERP, the piece includes additional express disclosure, in accordance with Article 64 of the Code:

32.2. The specific disclosure is included in the concise summary of the piece and in the full disclosures section.

Article 33. Disclosures relating to contractual relationships over the last 12 months

33.1. Each piece of research expressly declares the nature of the contractual relationships that EERP has maintained with the covered issuer during the last 12 months, including:

33.2. Contractual relationships that generate material revenue are identified qualitatively, without the need to disclose specific amounts subject to confidentiality, except where the 5% threshold of Article 31 is exceeded.

Article 34. Additional active transparency regime on portfolio composition

34.1. During the early financial years of EERP's operation, in which the portfolio may be concentrated in a small number of clients, EERP may publish on its website information on the qualitative composition of the portfolio of issuer clients, in accordance with Article 30.2 of the Code.

34.2. The information published includes, without disclosing individual identities subject to contractual confidentiality:

34.3. The information is updated at least annually and, where appropriate, upon material changes in the composition of the portfolio.

34.4. The additional active transparency regime persists during the early financial years and may be modulated or reduced when the portfolio attains sufficient diversification, by decision of the Sole Administrator following analysis by the Compliance Officer.

Article 35. Information to distributing investment firms

35.1. In accordance with Clause 7 of the EU Code, EERP makes available to the distributing investment firms, upon their request, the following information:

35.2. The information is provided diligently and, where it is of a confidential nature, under an appropriate confidentiality agreement.

35.3. EERP may, on its own initiative, commission from an independent external auditor an opinion on compliance with the EU Code, in accordance with Article 2(3)(a) of the Delegated Regulation of the EU Code, which is made available to the distributing investment firms in order to reduce the friction of verification.

TITLE VII. CONFLICTS OF INTEREST REGISTER

Article 36. Nature, format and medium of the Register

36.1. The Conflicts of Interest Register is the central operational document of this Policy. It is maintained in electronic format, managed by the Compliance Officer, in accordance with Clause 1(2) of the EU Code.

36.2. The technical medium of the Register allows for:

Article 37. Content of the Register

37.1. The Register records, for each identified conflict, the following minimum information:

37.2. The Register is updated by the Compliance Officer at each relevant milestone. Modifications are documented with date and authorship, without overwriting the historical information.

Article 38. Access to the Register

38.1. The Register is accessible:

38.2. Access is documented indicating person, date and scope, and is kept as part of the traceability of the Register.

Article 39. Preservation and historical traceability

39.1. The Register is kept for at least 5 years from the date of closure of each entry, in accordance with Clause 8 of the EU Code and Title XIII of the Code.

39.2. Historical entries are consultable and traceable. Modified versions preserve the original information in full.

39.3. In the event of a change of Compliance Officer (by replacement of the Sole Administrator or for any other cause), the integrity of the Register is transferred to the successor, with verification of operational continuity.

TITLE VIII. INVESTIGATION OF BREACHES AND NOTIFICATION TO THE ISSUER

Article 40. Detection of possible breaches

40.1. A breach of this Policy or of the regime of Title V of the Code is deemed identified where there are circumstances that reasonably suggest that:

40.2. Detection may come from any of the sources of Article 75.1 of the Code (direct detection by the Compliance Officer, whistleblowing channel, communication from a Subject Person, external communication from an issuer, distributing investment firm, supervisory authority or third party).

Article 41. Internal investigation procedure

41.1. Once the possibility of a breach is identified, the Compliance Officer opens an investigation file without undue delay from becoming aware of it, in accordance with Article 31.1 of the Code.

41.2. The investigation comprises:

41.3. The investigation guarantees the principle of presumption of innocence and the rights of defence of the persons involved.

Article 42. Notification to the issuer without undue delay

42.1. Where the Compliance Officer identifies a breach that may affect a piece of research, whether published or in progress, relating to a specific issuer, he informs the affected issuer without undue delay, in accordance with Clause 1(3) of the EU Code.

42.2. The notification to the issuer:

42.3. Where the breach affects multiple issuers or the published research generally, all affected issuers are notified.

Article 43. Corrective and disciplinary measures

43.1. Following confirmation of a breach, the Compliance Officer adopts or proposes, according to the severity:

Article 44. Articulation with the disciplinary regime of the Code

44.1. The internal disciplinary consequences of the breach are governed by Title XIV of the Code (Articles 73 to 76), applicable according to the seriousness of the breach (minor, serious, very serious).

44.2. The conflicts investigation file may be integrated with the disciplinary file where both concur, in all cases maintaining the procedural guarantees of Article 75 of the Code.

44.3. The effective application of sanctions depends on the specific provision in the individual contract, in the framework contract with External Analysts or in the Shareholders' Agreement, in accordance with Article 74.2 of the Code.

TITLE IX. GOVERNANCE OF THE POLICY ITSELF

Article 45. Initial approval and amendment

45.1. This Policy is approved by the Sole Administrator in accordance with Article 28 of the Articles of Association and enters into force on the date indicated in its approval.

45.2. Material amendments to the Policy are approved by the Sole Administrator, unless they affect matters reserved by the Articles of Association to the General Meeting of Partners.

45.3. Amendments are documented with date of approval, scope, reasoning and, where applicable, transitional provisions.

Article 46. Mandatory annual review

46.1. In accordance with Clause 1 of the EU Code, the Policy is reviewed on a mandatory annual basis. The review is carried out by the Compliance Officer with the support of the external Adviser and of the Internal Review Committee.

46.2. The annual review assesses:

46.3. The annual review culminates in a reasoned report by the Compliance Officer to the Sole Administrator and to the General Meeting of Partners, integrated into the annual reporting of Article 16 of the Code.

Article 47. Review upon material changes

47.1. In addition to the annual review, the Policy is reviewed whenever the following occur:

47.2. Interim reviews between annual reviews are documented with the same diligence as the annual review.

Article 48. Publication on the website

48.1. The version of the Policy in force is published on the corporate website of EERP in a section accessible to the public, in accordance with Article 28 of the Articles of Association.

48.2. The website indicates:

Article 49. Specific training on the Policy

49.1. Every Subject Person receives specific training on the Policy, integrated into the training of Article 77 of the Code:

49.2. The training is documented and kept in the personal file of the Subject Person.

Article 50. Annual reporting by the Compliance Officer

50.1. The Compliance Officer submits to the Sole Administrator and to the General Meeting of Partners, on an annual basis, a specific report on the Policy, integrated into the general reporting of Article 16 of the Code, which includes:

FINAL PROVISIONS

First Final Provision. Interpretation

1. The interpretation of the Policy rests, in the first instance, with the Compliance Officer, with the support of the external Adviser where necessary.

2. Interpretative doubts are resolved in the light of the Code (Title V), of the governing principles of this Policy (Title II) and of the applicable regulations, in favour of the option most protective of the investor and of market integrity.

Second Final Provision. Conflicts between the Policy, the Code and the applicable regulations

1. In the event of conflict between the Policy and the Code, the Code prevails.

2. In the event of conflict between the Policy and a rule of higher rank, the rule prevails.

3. If a provision of the Policy proves incompatible with supervening regulations, that provision shall be deemed amended or repealed to the extent necessary, without this affecting the remainder of the Policy.

Third Final Provision. Language

1. The official version of the Policy is the Spanish version.

2. EERP may prepare translations into other languages, in which case the Spanish version shall prevail in the event of discrepancy.

Fourth Final Provision. Operational support materials

The declaration forms, the disclosure templates, the format of the Conflicts Register and any other operational support materials necessary for the application of this Policy are approved and updated by the Compliance Officer where he deems it appropriate. Their preparation does not constitute a condition of the validity or application of the Policy.

Fifth Final Provision. Transitional regime

1. This Policy applies directly from its entry into force, filling operational gaps by means of interpretation in accordance with its governing principles and with the Code.

2. The Compliance Officer approves the necessary operational support materials within a reasonable period, without their absence impeding the full application of the Policy.