Code of Ethics

Last updated: January 1, 2026

Purpose and scope

This Code of Ethics sets out the standards of conduct expected of all Prime Summa officers, directors, employees, and, where applicable, contractors and consultants. It reflects a simple premise: we are entrusted with other people's capital, and that trust imposes obligations beyond what any rule can specify.

Where this Code and applicable law or regulation differ, the stricter standard applies.

Integrity

We deal honestly and fairly with investors, counterparties, colleagues, regulators, and the public. We do not misrepresent facts, omit material information in a way that misleads, or make claims we cannot support.

We describe risk as plainly as opportunity, and we correct errors promptly when we discover them.

Fiduciary responsibility

We place the interests of investors ahead of our own and ahead of the firm's. Where a decision could benefit us at an investor's expense, the investor's interest governs.

This duty applies to investment decisions, allocation of opportunities, valuation, expense allocation, and the communication of information.

Compliance with law

All personnel are required to comply with applicable laws, regulations, and firm policies. Ignorance of an applicable requirement is not a defense, and no business objective justifies a violation.

Personnel must not engage in, or assist any other person to engage in, insider trading, market manipulation, fraud, bribery, or corrupt practices.

Confidentiality

Information about investors, transactions, counterparties, and the firm's own affairs is confidential. It may be used only for legitimate business purposes and may be disclosed only to those with a need to know or as required by law.

Confidentiality obligations continue after employment ends. Material non-public information must not be used for personal benefit or communicated to anyone not authorized to receive it.

Conflicts of interest

Conflicts of interest are inevitable in an investment business; concealing them is not acceptable. Personnel must identify actual and potential conflicts promptly and disclose them to the Chief Compliance Officer.

Areas requiring disclosure include:

• Outside business activities, directorships, and employment
• Personal investments that overlap with firm activity
• Family or personal relationships with counterparties, vendors, or investors
• Referral arrangements and any compensation associated with them
• Allocation of investment opportunities among the firm, its personnel, and investors

Conflicts are addressed by avoidance, mitigation, or clear disclosure. Where a conflict cannot be eliminated, investors are informed of it.

Personal trading

Personal investment activity must never conflict with the interests of investors or make improper use of information obtained through employment. Personnel are subject to reporting, preclearance, holding period, and restriction requirements as set out in firm policy.

Personnel may not trade ahead of the firm, use knowledge of pending transactions for personal benefit, or participate in an opportunity that properly belongs to investors.

Gifts, entertainment, and payments

Personnel may not give or accept gifts, entertainment, or anything of value that could improperly influence a business decision or create the appearance of doing so. Gifts and entertainment above defined thresholds must be reported and, in some cases, preapproved.

Improper payments of any kind, including facilitation payments, are prohibited without exception. Political contributions are subject to preclearance where applicable rules require it.

Professional conduct

We treat colleagues, counterparties, and communities with respect. Harassment, discrimination, retaliation, and abusive conduct are not tolerated.

Personnel are expected to maintain the competence required for their role, to exercise independent professional judgment, and to raise concerns rather than defer to seniority or convenience.

Accurate records and reporting

Books, records, valuations, expense allocations, and investor communications must be accurate, complete, and produced in accordance with applicable standards. No one may create a false or misleading record or conceal information from auditors, regulators, or internal reviewers.

Reporting violations

Personnel are required to report suspected violations of this Code, of firm policy, or of applicable law. Reports may be made to a supervisor, to the Chief Compliance Officer, or through the firm's confidential reporting channel.

Retaliation against any person who raises a concern in good faith is prohibited and is itself a serious violation of this Code.

Third parties may raise concerns by writing to [email protected].

Acknowledgment and enforcement

All personnel acknowledge this Code upon joining the firm and periodically thereafter. Violations are investigated and may result in disciplinary action up to and including termination, as well as referral to regulators or law enforcement where appropriate.

This Code is reviewed periodically and updated as the firm's activities and the regulatory environment change. See also our compliance program.