KYC Policy — Caldoun Capital

Last updated — November 2025

1. Identification and verification

For individual clients we collect and verify full legal name, date of birth, residential address, occupation and government-issued identification, using reliable independent source documents, data or information, or one of the other verification methods permitted under the PCMLTFA regulations.

For entity clients (corporations, partnerships, trusts and other entities) we obtain and verify legal name, address, constating documents, directors and senior officers, and information about the ownership, control and structure of the entity, including the identity of individuals who directly or indirectly own or control 25% or more of the entity or otherwise exercise ultimate effective control.

2. Investor-status verification

Where an exemption from prospectus or registration requirements is being relied upon (for example, the "accredited investor" or "permitted client" exemption), we obtain the information reasonably necessary to confirm that the exemption is properly available and retain records of that assessment.

3. Suitability and Know-Your-Product

Where suitability obligations apply, we collect information about the client's personal and financial circumstances, investment needs and objectives, investment knowledge, risk profile and time horizon, and consider such information together with the features, structure, risks and costs of any product being considered.

4. Ongoing information

Clients are asked to notify us promptly of material changes to the information they have provided. We periodically review client information to ensure it remains accurate, current and complete.

5. Refusal or termination

We may decline or terminate a relationship, or refuse to process a transaction, if we are unable to satisfactorily complete our KYC or verification procedures.

6. Privacy

Personal information collected for KYC purposes is handled in accordance with our Privacy Policy.

Know-Your-Client (KYC) Policy