Conflict Management Policy

Background

IMPACTLAKE Pte. Ltd. and IMPACTLAKE Co. Ltd. (collectively referred to as “our company”) provide and operate various services and solutions that play a role as infrastructure primarily within the financial and capital markets. Therefore, our business operations require the reliability of information, transparency of processes, and a high level of compliance literacy among all stakeholders. Given this context, the Company manages conflicts of interest or potential conflicts in accordance with this Policy, tailored to the nature, characteristics, and scale of its operations, to ensure the interests of stakeholders are not harmed.

Premise

IMPACTLAKE Pte. Ltd. operates neutral businesses such as product development and platform management, while IMPACTLAKE Co. Ltd. provides various support services, primarily consulting, to specific companies. This structure minimizes functional conflicts of interest.

The Impact Management Open Platform operated by IMPACTLAKE Pte. Ltd. is positioned solely as a neutral, non-competitive functional database. It discloses and publishes information to investors, issuers, and other entities based solely on the parties’ intentions or agreements with them. Our company does not evaluate, interpret, or disclose information contrary to the parties’ intended purpose without their agreement. and other entities based solely on the parties’ intentions or agreements with the parties. Our company will not conduct any evaluation, interpretation, or disclosure/publication of information on this platform that differs from the parties’ intended purpose without their agreement.

Similarly, regarding the Impact Management Agent also operated by the company, while it may provide benefits in competitive domains for each company, it does not develop functions tailored solely to the needs of individual organizations. Its fundamental positioning is to provide, for a fee, functions that enhance user convenience among those with high overall demand within the domain.

Meanwhile, IMPACTLAKE Co. Ltd. provides impact-related consulting services to individual companies and organizations. In delivering these solutions, we go beyond basic information management for matters of importance. For information deemed strategically significant or highly unique, we rigorously enforce cross-client information management. Furthermore, information obtained about a client for service delivery, including consulting services, will not be used for other purposes unless we have obtained the client’s specific consent or have confirmed that equivalent or greater disclosure has already been made by the client.

Furthermore, we are not an external evaluation agency providing scoring or ratings; we are an organization that operates to maximize the interests of individual companies (meaning not specific individual companies). Therefore, the neutrality and independence guaranteed on our platform differ from the neutrality and independence of evaluation processes, standards, and opinions typically associated with external rating agencies. Our neutrality and independence are based on compliance with customer preferences regarding information handling and ensuring the accuracy of information content. Our conflict of interest policy is established on this premise.

How to Manage Conflict

Our company will strive to prevent harm arising from conflicts of interest and ensure that the interests of stakeholders are not harmed by selecting and appropriately combining the methods listed below.

• Methods for separating departments that engage in activities involving conflicts of interest or potential conflicts of interest (specified activities) from other departments
• Methods for excluding personnel responsible for activities involving conflicts of interest or potential conflicts of interest (specified activities) from their duties
• Methods for changing the conditions or methods of activities involving conflicts of interest or potential conflicts of interest (specified activities)
• Methods for discontinuing activities that constitute conflicts of interest or pose a risk thereof (specified activities)
• Methods for disclosing that the interests of relevant parties may be harmed as a result of activities that constitute conflicts of interest or pose a risk thereof (specified activities)

Type of Conflict

Our company not only complies with prohibited acts stipulated by law, but also proactively manages conflicts of interest by categorizing such conflicts or potential conflicts in advance through appropriate methods. This is done to prevent harm to the interests of relevant parties, even in cases where the acts do not fall under the prohibited acts.

• Fiduciary Duty Type: When our company or its affiliates may gain economic benefits or avoid economic losses at the expense of the customer. Or when, in transactions with the customer, we receive or are likely to receive inducements in the form of money, goods, or services from parties other than the customer, beyond normal fees or expenses.
• Self-Dealing Type: When the Company or its affiliates engage in transactions with customers they are obligated to protect.
• Dual Agency Type: When the Company or its affiliates engage in transactions on behalf of the counterparty to a transaction with a customer they are obligated to protect.
• Competing Transaction Type: When the Company or its affiliates engage in transactions with a counterparty of a customer they should protect, which compete with the customer.
• Information Utilization Type: When the Company or its affiliates engage in transactions to gain their own benefit through the use of non-public information of a customer they should protect.
• Transaction Internalization Type: When the Company or its affiliates participate in the same transaction in multiple capacities, making it impossible to expect transactions under the same conditions as a normal transaction.

Main Examples of Potential Conflict of Interest Risks and Countermeasures

Whether a conflict of interest exists should be determined based on the specific circumstances of each case. However, for risks anticipated in business operations and potential incidents, we have established the following response policies in advance.

Risks anticipated	Type	Directions
Cases where information obtained from either the business operator (issuer) or the investor is utilized for services provided to the other party, based on the assumption of consent from that business operator (issuer) or investor.	Dual-agency / Information-utilization	Clearly identify the source of the request (beneficiary of the service) on a case-by-case basis and strictly enforce fee collection from only one party.
Cases where we provide advisory services to both specific investors and their portfolio companies	Dual-agency	Thorough information management through the separation and independence of related internal organizations, maximizing profits for each customer
Cases where our company independently conducts sales activities or proposes various services to customers with whom we have established relationships through our collaborative partners (such as consulting firms).	Competing Transaction	Establish specific rules and obtain agreements in contractual relationships with each partner (consulting firms, etc.)
Using non-public information obtained through one’s duties to seek personal gain or avoid loss in the purchase, sale, or other transactions of securities	Fiduciary Duty / Information Utilization	Disclosure and non-disclosure management based on customer intent, thorough information management through separation and independence of relevant internal organizations, prohibition of insider trading, etc.

(Latest Update: 2025/12/31)