General Privacy Notice

Code of Ethics

Conflicts of Interest Policy

Finance Policy

Governance Policy

Information and Trading Policy

Information Security and Data Privacy Policy

McKinsey River Capital Management Responsible Investment & Ownership Policy

Modern Slavery Act Statement (where applicable)

Global Workplace Health and Safety Guidelines

Anti-Bribery & Corruption Guidelines

Diversity and No-Harassment Guidelines

Tax Guidelines

Business Partner Code of Conduct

Remuneration Public Disclosure Statements (where applicable)

Risk Management Guidelines

Anti-Bribery & Corruption

McKinsey River Capital Management is committed to complying with applicable anti-corruption and anti-bribery laws wherever it conducts business. McKinsey River Capital Management does not accept, offer, request, or authorize bribes in any form.

Political contributions, gifts, and business entertainment may be considered forms of bribery depending on local law and context. McKinsey River Capital Management maintains internal guidelines governing gifts, hospitality, and interactions with public officials. All gifts or business entertainment offered or received by staff must comply with applicable internal approval processes and documentation requirements.

These guidelines apply to all staff and are designed to prevent improper influence, including where interactions involve public sector counterparties or state-owned entities, and to ensure that McKinsey River Capital Management does not obtain business or favorable treatment in exchange for political contributions, fundraising assistance, or any improper benefit.

To promote sustainability in our industry and support constructive public discourse, McKinsey River Capital Management may participate in industry associations, working groups, and related initiatives.

Trade associations & partnerships (disclosure):

McKinsey River Capital Management’s contributions to trade associations and partnerships are disclosed in accordance with applicable transparency expectations and internal governance practices.

The contributions primarily consist of membership fees and dedicated studies. The three largest contributions during 2024 were made to:
[Partner 1], [Partner 2], [Partner 3].

Political contributions:

McKinsey River Capital Management does not make political contributions to political parties, political organizations, or election candidates. No such donations have been made from [Year] to date.
While McKinsey River Capital Management does not participate in party political activities, we may engage in policy discussions on subjects that affect our mission, stakeholders, and the communities in which we operate.

Disclaimer regarding historical data:

Where disclosures include historical information, earlier periods may reflect different structures, subsidiaries, or reporting boundaries.
Because contributions consist mainly of membership fees, detailed lobbying disclosure may not always be feasible.

Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF)

McKinsey River Capital Management is committed to preventing money laundering and terrorist financing and to complying with applicable AML/CTF laws relevant to our activities and business relationships.

We maintain an AML/CTF program comprised of appropriate policies, procedures, training, and controls to help prevent, detect, and manage risks relating to financial crime, sanctions breaches, money laundering, and related risks.

To ensure proper oversight, McKinsey River Capital Management designates responsible compliance personnel to manage due diligence processes and program governance.

We apply a risk-based approach to determine:

• the scope of due diligence,

• the level of ongoing monitoring, and

• whether enhanced measures are required.

Enhanced due diligence may be applied where relationships involve:

• High-risk jurisdictions

• Complex ownership structures

• Politically exposed persons (PEPs)

• Correspondent relationships (where applicable)

• Other elevated risk indicators

Relationships involving PEPs are subject to dedicated monitoring and appropriate approvals.

Screening may include:

• UN & EU sanctions lists

• OFAC (U.S. Treasury Department)

• PEP databases

• Other risk intelligence sources

All AML/CTF documentation is retained for at least five (5) years or longer as required.

Global Disciplinary Misconduct Framework

McKinsey River Capital Management maintains a Global Disciplinary Misconduct Framework covering conduct that materially conflicts with our values, policies, and procedures. This includes misconduct related to:

• Fraud

• Financial crime

• Legal or regulatory breaches

• Data incidents

• Employment practice violations

The framework ensures:

• Proper escalation

• Consistent case assessment

• Clear documentation

• Structured resolution process

Cases may involve HR, Legal, Compliance, and relevant governance bodies (e.g., an audit committee).
Periodic reporting (e.g., quarterly) may be provided to oversight functions.

Shareholder Rights Directive (SRD II) – Where Applicable

Where applicable, McKinsey River Capital Management or affiliated entities may assess the applicability of SRD II and evaluate whether to develop and publish a shareholder engagement policy.

Whistleblowing

McKinsey River Capital Management maintains:

• External whistleblowing instructions

• External whistleblowing channels

Details are available here: [Whistleblowing Link Placeholder]

Information Security Governance

McKinsey River Capital Management recognizes that cybersecurity and information security are strategic enablers of trust and resilience. We are committed to protecting stakeholders, partners, and systems from cyber and operational risks.

Security governance supports:

• Digital infrastructure resilience

• Stakeholder confidence

• Long-term value creation

Information Security Management Program

Our Information Security Management Program includes:

• Business continuity

• ICT risk management

• Vulnerability management

• Internal controls

• ICT resilience strategy

• Risk identification and classification

• Incident escalation procedures

• Designated approval paths

• Tabletop exercises

Our program is informed by global frameworks, including:

• ISO/IEC 27001

• NIST Cybersecurity Framework

• EU DORA (where applicable)

Vulnerability Management

Includes:

• Automated scanning

• Manual penetration testing

• Risk-based prioritization

• Documented remediation timelines

Enterprise Risk Management (ERM) Integration

Cybersecurity is embedded into ERM.
Control effectiveness is evaluated through assessments, evidence, and analytics.

Training

All staff undergo annual security awareness training.

Independent Review

Selected systems may undergo external audits or certifications.

Transparency and Breach Disclosure

McKinsey River Capital Management confirms that there were no material information security breaches in FY2024.