Conflicts of Interest Policy

Last updated — November 2025

Our approach

We are committed to identifying material conflicts of interest that exist, or that we reasonably expect to arise, between Caldoun Capital Inc. (including our directors, officers, employees and agents) and our clients, or between one client and another, and to addressing those conflicts in the client's best interest.

Identification

Personnel are required to identify and escalate potential material conflicts to the Chief Compliance Officer. A conflicts inventory is maintained and reviewed periodically.

Addressing conflicts

Material conflicts are addressed by (a) avoiding the conflict where it cannot be otherwise adequately managed; (b) controlling the conflict through information barriers, allocation policies, supervision, approval processes or other measures; and (c) disclosing the conflict to affected clients in a manner that is timely, prominent, specific and written in plain language.

Examples

Illustrative examples of conflicts that may arise include: compensation structures that could influence recommendations; referral arrangements; personal trading by personnel; related-party transactions; allocation of limited investment opportunities among clients; and outside business activities of personnel. Each is subject to specific controls appropriate to its nature and materiality.

Gifts, entertainment and outside activities

Personnel are subject to policies governing gifts and entertainment, personal trading, and outside business activities, designed to prevent, mitigate or disclose conflicts of interest.

Questions

Questions about this Policy or about a particular conflict of interest can be directed to info@caldouncapital.ca.