Disclosure & Conflict of Interest Policy

This Disclosure & Conflict of Interest Policy (“Policy”) outlines the principles by which Paligan c/o Weiss Group LLC (“Paligan”) identifies, discloses, and manages actual or potential conflicts of interest. The purpose of this Policy is to uphold the integrity, independence, and credibility of Paligan’s activities, particularly in light of the external professional affiliations held by its Covered Persons.

Paligan operates discreetly within the private markets space, often in parallel with the professional commitments of its founders and board members. This Policy ensures that such dual engagements do not compromise ethical standards or stakeholder trust.

This Policy applies to all individuals who hold a fiduciary, decision-making, or representational role within Paligan (“Covered Persons”). This includes the founder(s), members of the board of directors, and any person formally empowered to make binding decisions on behalf of the organization.

A conflict of interest arises when a Covered Person’s personal, professional, or financial interests could compromise—or appear to compromise—their impartiality, independence, or ability to act in the best interest of Paligan.

Many Covered Persons may hold roles outside of Paligan, including employment or board memberships in third-party organizations. To preserve independence and transparency:

• Covered Persons must ensure that their engagement with Paligan is fully disclosed to and, where applicable, approved by their external employer(s);

• Paligan shall not provide services that compete directly with the offerings of organizations employing the Covered Persons;

• Paligan’s activities must remain operationally distinct from those of any affiliated external entity.

To avoid both actual and perceived conflicts of interest, Paligan observes the following principles:

• Non-Competition: Paligan shall not engage in commercial activities that conflict with the services, clients, or mandates of Covered Persons’ primary employers;

• Service Differentiation: Paligan’s operational model, deal selection, and investment strategy are structured to remain independent of any employer-affiliated mandates or internal activities.

Paligan has established procedures to ensure ongoing monitoring and compliance with this Policy:

• Annual Declaration: Covered Persons shall submit an annual declaration outlining any professional roles that could intersect with Paligan’s operations;

• Ad Hoc Disclosure: Any new potential conflict must be disclosed immediately upon arising;

• Pre-Activity Review: All new business activities proposed at Paligan must be reviewed for potential conflicts before being pursued;

• Ongoing Oversight: Paligan shall monitor its own operations to ensure alignment with this Policy.

Any concerns, uncertainties, or required disclosures relating to this Policy may be submitted in writing to: legal@paligan.com.

Paligan is not affiliated with any external employer or organization connected to its Covered Persons. To reinforce this independence:

• Paligan shall not use, promote, or imply the brand identity, logo, or institutional credibility of any such external organization;

• Paligan shall not suggest endorsement, partnership, or backing by external employers of its Covered Persons;

• All communications shall clearly distinguish Paligan’s work as separate and unrelated to any external employment activities.

Where applicable, Paligan voluntarily adopts certain ethical safeguards and restrictions from the institutional frameworks of Covered Persons’ employers, including:

• Restricted Investments: Paligan shall not invest in companies or securities that are restricted by the Covered Persons’ employers or their clients;

• Blackout Periods: Paligan shall adhere to any blackout periods on trading or strategic activity relevant to Covered Persons;

• Non-Engagement with Employer Clients: Paligan shall not knowingly pursue business relationships with clients of Covered Persons’ employers or their affiliate networks.

Paligan will periodically review this Policy to ensure its continued relevance and adequacy. Violations of this Policy may result in internal review and, if warranted, termination of authority or exclusion from decision-making activities.

By continuing to serve in their respective roles, Covered Persons acknowledge and agree to adhere to this Policy in full.