CONFLICTS OF INTEREST POLICY

Created: 14.7.2025

Management of conflicts of interest at Kvarn Capital

Kvarn Capital Ltd. (“Kvarn”) recognizes various situations where its own interests or those of its personnel may conflict with the interests of its customers. These situations are particularly related to the services offered by Kvarn and their specific characteristics.

Potential conflict of interest situations and their nature

Conflicts of interest may arise, for example, in the following situations:

• Financial gains and losses: The financial interests of Kvarn or its personnel may guide decisions that do not align with the customer's interests. This can occur, for example, by favoring services that generate more revenue for Kvarn at the customer's expense.
• Unequal treatment of customers: Customers may be treated unequally if personal relationships of personnel or pressure from shareholders influence decisions, which may favor certain customers at the expense of others.
• Competitive situations with customers: Kvarn may engage in activities that compete with the customer's interests. This can lead to a situation where Kvarn's decisions prioritize its own interests over those of the customer.
• Outsourced entities and third-party service providers: A conflict of interest may arise if an outsourced entity prioritizes its own interests over those of the Company and its customers, which can impair service quality and affect impartiality.

Identified risks

Identified conflicts of interest could pose the following risks to Kvarn's customers:

• Impairment of fairness: Customers may receive unequal service.
• Weakening of customer relationships and reputation: Customers' trust in Kvarn may diminish, which can affect long-term customer relationships.
• Financial losses for customers: Customers may suffer financial damage if decisions are weighted towards Kvarn's own benefit.

Preventive and mitigating measures

Kvarn has implemented the following measures to prevent and mitigate conflicts of interest:

• Clear operating principles: Kvarn has rules and guidelines that prohibit the acceptance of gifts and benefits, as well as the influence of personal relationships on decision-making.
• Segregation of functions: Kvarn ensures that certain business operations and decision-making roles are segregated to prevent role conflicts from affecting impartiality.
• Regular assessment and reporting: Kvarn annually assesses the effectiveness of its conflict of interest management measures and updates its operating principles and arrangements as necessary.

Accessibility and updates

Kvarn keeps this information up to date, and customers can review all measures and principles on Kvarn's website and via various devices.