Policy

Code of Ethics

Effective: April 2026 Owner: Chief Compliance Officer Applies to: All Telvo entities

Purpose

Telvo's Code of Ethics establishes the ethical standards applicable to all Telvo personnel across the platform's operating company, investment manager, and fund vehicles. The Code is grounded in fiduciary duty, loyalty to LPs, honesty in all professional dealings, and integrity in every underwriting and asset management decision.

Standards of Conduct

All Telvo personnel are expected to act in the best interests of Telvo fund vehicles and their limited partners, avoid conflicts of interest, treat carrier customers and property partners fairly, protect confidential information, and comply with applicable laws and regulations.

Personal Trading

Personnel with access to material non-public information about Telvo investments, transactions, or fund activity are subject to personal trading restrictions, pre-clearance requirements, and reporting obligations.

Gifts and Entertainment

Personnel may accept nominal gifts and reasonable business entertainment in the ordinary course but must decline anything that could reasonably be perceived to influence business decisions. All material gifts and entertainment are logged.

Reporting Violations

Personnel are required to report suspected violations of the Code of Ethics through direct escalation, the Chief Compliance Officer, or the confidential whistleblower channel described in Telvo's Whistleblower Policy.

Enforcement

Violations of the Code of Ethics may result in disciplinary action including termination and referral to regulatory authorities where warranted.