SUSTAINABILITY

CODE OF CONDUCT

Vicus Capital Advisors' Code of Conduct is a set of rules outlining our environmental, social and financial norms and responsibilities. Our sustainability work is guided by our Code of Conduct and it also applies to our cooperation parties.

We take care of our customers' interests and develop our operations with customers' needs in mind
We promote the implementation of the Principles for Responsible Investment
We are utterly opposed to bribery and corruption, and have zero tolerance to money laundering
We respect privacy and secure confidential information
We care about the environment and act to combat climate change

We identify and prevent conflicts of interest

We commit and expect fair and honest dealing in all our interactions

We commit ourselves to open and clear communication

DISCLOSURES UNDER THE REGULATION (EU) 2019/2088 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL

Article 3: Vicus Capital Advisors does not have in place policies on the integration of sustainability risks in our investment decision‐making process.

Article 4: Vicus Capital Advisors does not consider adverse impacts of investment decisions on sustainability factors.

Vicus Capital Advisors is highly committed to developing advanced ESG policies for investment decision-making and identification of adverse impacts of its investment decisions. However, the investment periods for the funds currently managed by Vicus Capital Advisors have expired and these funds do not make any new investments. Therefore, there is currently no need for ESG-related decision-making policies or consideration of adverse impacts of investment decisions on sustainability factors.

For any future funds managed by Vicus Capital Advisors, policies on the integration of sustainability risk in the investment decision-making process will be established and the adverse impacts of investment decisions on sustainability factors will be considered. Information on these policies will be published on this website.