Conflict of Interest Management Policy

This policy sets out how Southcity Capital Management (Pty) Limited, an Authorised Financial Services Provider (FSP 52877), identifies and manages actual, potential and perceived conflicts of interest. It applies to directors, employees, Investment Committee members and associated persons.

Conflicts may arise between the interests of the manager and a fund, between funds, between investors, or through personal interests, outside appointments, related-party relationships, gifts or inducements. Identified conflicts are recorded in a conflicts register.

Conflicts are avoided where possible. Where a conflict cannot be avoided, it is mitigated through controls such as recusal from decision-making, independent review, and referral to an Investment Committee with an independent majority or to the relevant Limited Partner Advisory Committee. Material conflicts are disclosed to affected investors.

Related-party transactions require disclosure, independent assessment of terms and approval in accordance with the related-party transaction policy. Affected persons take no part in the approval decision.

Compliance oversight includes maintenance of the conflicts register, monitoring of controls, periodic review of this policy and reporting to the board. Concerns may be reported to the compliance officer via directors@southcitygroup.co.za.