Conflicts of Interest Policy.

01Why this policy matters

Conflicts of interest naturally arise in any business that handles client assets or advises on financial decisions. The way a firm handles conflicts is one of the most important indicators of how it treats its clients.

Our position is straightforward: conflicts cannot always be eliminated, but they can almost always be identified, disclosed, and managed. Where they cannot, we must decline the business or the activity that gives rise to the conflict.

02Our approach

We follow a four-step process for every potential conflict:

1. Identify the conflict, ideally before it materialises
2. Manage it through structural controls (independence, oversight, segregation), procedural controls (approvals, blackouts, escalation), or, where necessary, declining the business
3. Disclose the conflict to affected clients in writing, in plain language, before they decide whether to proceed
4. Record the conflict in our conflicts register and review periodically

Disclosure alone is not sufficient. If a conflict cannot be effectively managed, we will not rely on disclosure to make the activity acceptable.

03Types of conflicts we identify

• Firm vs client: our financial or other interest may differ from a client's interest
• Client vs client: the interests of two clients may conflict (for example, in allocating limited primary auction supply)
• Staff vs firm or client: a staff member's personal interest may differ from the firm's or a client's
• Group conflicts: where our affiliates or partners have interests that differ from those of a client
• Inducements: commissions, rebates, or non-monetary benefits we receive that could influence our advice

04Specific conflicts and how we manage them

4.1 Partner-bank referral arrangements

We have written referral arrangements with Ecobank Ghana, Stanbic Bank Ghana, and GCB Bank. Where we refer a client to a partner bank for deposit, foreign-currency, or credit services, we may receive a referral fee from that bank.

Conflict: our interest in earning the referral fee could influence our recommendation of which bank to refer you to.

How we manage it:

• We disclose the existence of referral fees and the arrangement to every client at onboarding and again at the point of any specific referral
• We disclose, on request, the broad fee structure (we do not always disclose the specific amount per referral)
• Referrals are made on the basis of suitability for the client's need, not on which partner pays the highest referral fee
• The decision to extend credit or open a deposit rests entirely with the partner bank

4.2 Allocation of investment opportunities

From time to time we have access to investments (such as primary auction allocations) that exceed available client demand or fall short of it.

Conflict: the firm's own account or a favoured client could be preferred over other clients.

How we manage it:

• We do not run a proprietary trading book that competes with client orders
• Allocations are made by pre-agreed methodology (typically pro-rata to expressed interest, with stated tie-breakers)
• Allocations are reviewed by Compliance after the fact for adherence to methodology

4.3 Best execution and pricing

For trades executed through our partner banks or other counterparties, we have an interest in maintaining those relationships.

Conflict: we could prioritise a counterparty relationship over the best price for the client.

How we manage it:

• We follow a documented Best Execution Policy that requires obtaining the best available terms for the client
• For larger trades, we take competing quotes from multiple counterparties
• Best execution outcomes are subject to periodic review by Compliance

4.4 Suitability

Some products generate higher fees for the firm than others.

Conflict: we could recommend higher-fee products to a client where lower-fee products would also or better suit them.

How we manage it:

• Recommendations are documented with the rationale, including why the recommended product was preferred over alternatives
• Adviser remuneration is not linked to product margin
• Periodic suitability reviews are conducted by Compliance independent of the original adviser

4.5 Research independence

Our research function publishes views that may affect investment decisions.

Conflict: research could be slanted to support firm or affiliate positions.

How we manage it:

• Research operates with reporting independence from any business unit whose performance could be affected by research output
• Research analysts disclose personal holdings in covered names
• Research distribution is timed so no internal user has an unfair advantage over clients

4.6 Affiliate transactions

From time to time we may transact with affiliated entities, where any such affiliates exist.

How we manage it: any transaction with an affiliate is conducted on arm's-length terms and pre-approved by Compliance, with the rationale documented.

4.7 Pricing of in-house funds

We may recommend in-house funds (PCI Money Market Fund, PCI Fixed Income Fund, etc.) where appropriate.

Conflict: in-house funds generate management fees for the firm.

How we manage it:

• The fees of all in-house funds are publicly disclosed in the fund offering documents
• In-house funds are recommended only when they fit the client's stated objectives, alongside genuine consideration of third-party alternatives
• The use of in-house funds is reviewed by Compliance for any pattern of inappropriate concentration

05Personal account dealing

All staff are subject to a Personal Account Dealing Policy, which:

• Requires staff to disclose all securities accounts they or their immediate family hold
• Prohibits trading in securities while in possession of material non-public information
• Requires pre-clearance for trades in covered securities
• Imposes blackout periods around firm activity (publication of research, large client orders, primary market participation)
• Prohibits short-term trading by staff

Breaches of the policy are subject to disciplinary action, up to and including dismissal, and may be reported to authorities where the law requires.

06Gifts and entertainment

We maintain a Gifts and Entertainment Policy that:

• Sets monetary thresholds above which gifts cannot be given or accepted
• Prohibits cash gifts in any amount
• Requires logging of all gifts given or received above a low threshold
• Imposes additional restrictions for gifts to or from public officials and PEPs

Gifts and entertainment must never be intended, or capable of being seen, as inducement to act other than in the client's best interest.

07Outside business activities

Staff must obtain approval before taking on outside roles (directorships, employment, business interests, public office). The Compliance Officer reviews each request for potential conflict with the staff member's duties to clients and the firm.

08Information barriers

We operate information barriers ("Chinese walls") between functions where the sharing of information could create or exacerbate conflicts. For example, between corporate finance advisory and asset management. Information held on one side of the barrier is not shared with the other except through controlled procedures involving Compliance.

09Conflicts register

Compliance maintains a Conflicts Register that records:

• Identified conflicts, both standing (structural) and case-by-case
• The control or management technique applied to each
• The disclosures made to clients
• Any incidents where the conflict crystallised, with root-cause analysis

The Register is reviewed quarterly by the MLRO/Compliance Officer and at least annually by the Audit & Risk Committee.

10Disclosure to clients

Where a conflict could materially affect a client's interests, we disclose it in writing, in plain language, before the affected service is provided or the affected transaction is concluded. Disclosure includes:

• The nature of the conflict
• The steps we have taken to manage it
• Any residual risk to the client
• The client's right to ask for additional information or to decline

We do not consider disclosure to be a substitute for management. If we cannot manage a conflict adequately, we will not rely on disclosure to proceed.

11Where conflicts cannot be managed

If a conflict cannot be managed in a way that protects the affected client's interests, we will:

• Decline to act on the affected matter, or
• Resign from the affected mandate, or
• Refer the client to another firm, with full disclosure of why

The decision to decline or resign is made at senior management level, with input from Compliance.

12Reporting concerns

Clients, staff, counterparties, and members of the public who have concerns about a possible conflict of interest can:

• Email the Compliance Officer at compliance@premiumcapitalgh.com
• Use the confidential whistleblowing channel at whistleblower@premiumcapitalgh.com
• Write to the Chair of the Audit & Risk Committee, marked private

Whistleblower protections under the Whistleblower Act, 2006 (Act 720) apply to good-faith reports.