Policy

Conflicts of Interest

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

Framework

Telvo operates across multiple fund vehicles, each with distinct mandates and Limited Partners. Conflicts of interest can arise in deal origination, allocation, valuation, and cross-fund transactions. Telvo's Conflicts of Interest policy establishes principles and procedures for identifying, disclosing, and resolving such conflicts.

Deal Allocation

Deal allocation among Telvo fund vehicles follows written allocation guidelines based on each fund's mandate, remaining investment capacity, concentration limits, and portfolio construction objectives. Cross-fund allocations require Conflicts Committee approval and LP Advisory Committee consultation where applicable.

Cross-Fund Transactions

Transactions between Telvo fund vehicles (e.g., asset sales from one fund to another) require independent third-party valuation, Conflicts Committee approval, and LP Advisory Committee consent under each affected fund's LPA.

Related-Party Transactions

Transactions between Telvo fund vehicles and Telvo personnel, affiliates, or family members are prohibited absent Conflicts Committee approval, LP Advisory Committee consent, and disclosure in quarterly LP reporting.

Disclosure

All identified conflicts, including the manner of resolution, are disclosed to affected Limited Partners through quarterly reporting and, where material, through interim LP notices.