1. Purpose

The Anti-Money Laundering, Know Your Customer, and Sanctions Policy establishes the firm's program for detecting and preventing money laundering, terrorist financing, sanctions violations, and other financial crime. The policy is designed to comply with the Bank Secrecy Act, the USA PATRIOT Act, the Office of Foreign Assets Control sanctions regulations, and applicable state and non-U.S. anti-financial-crime laws.

2. Scope

This policy applies to all funds, vehicles, and accounts managed or advised by Slate Blue Capital LLC and its affiliates, to all personnel of the firm, and to all subscriptions, distributions, transfers, and other transactions involving fund interests. Counterparties, vendors, portfolio companies, and other relationships are also subject to screening as described below.

3. AML Compliance Officer

The Chief Compliance Officer serves as the firm's AML Compliance Officer and is responsible for the design, implementation, oversight, testing, and continuous improvement of the firm's anti-money-laundering program. The AML Compliance Officer reports to the Chief Executive Officer with a dotted-line reporting relationship to the Audit Committee on AML matters.

4. Customer Identification and Verification

Before accepting any subscription, the firm verifies the identity of the prospective investor and any beneficial owners of legal entity investors. For natural persons, verification includes government-issued identification, date of birth, residential address, taxpayer identification number, and source of funds. For legal entities, verification includes formation documents, ownership structure to the level of natural-person beneficial owners holding twenty-five percent or more of the entity, and certification of beneficial ownership under the Corporate Transparency Act and FinCEN rules where applicable.

5. Enhanced Due Diligence

Enhanced due diligence is applied to investors that present elevated risk, including politically-exposed persons and their close associates and family members, investors domiciled in jurisdictions identified by the Financial Action Task Force as high-risk or non-cooperative, investors whose source of wealth or source of funds is not readily verifiable, complex offshore ownership structures, and any subscription where the firm identifies indicators of elevated financial-crime risk. Enhanced due diligence is documented and retained.

6. Sanctions Screening

All investors, beneficial owners, counterparties, portfolio company counterparties, and material vendors are screened against the Specially Designated Nationals and Blocked Persons List maintained by the Office of Foreign Assets Control, the Consolidated Sanctions List of the European Union, His Majesty's Treasury Consolidated List, and other applicable sanctions lists. Screening is conducted at onboarding, on the addition of any new beneficial owner, on a periodic refresh basis, and upon updates to applicable sanctions lists. A match or potential match triggers immediate escalation to the AML Compliance Officer.

7. Suspicious Activity Reporting

Personnel who become aware of activity that may be suspicious, including unusual subscription or redemption patterns, third-party funding of subscriptions, requests to transfer funds to unrelated parties, or other red flags, shall report such activity to the AML Compliance Officer immediately. The AML Compliance Officer evaluates each report and, where appropriate, files a Suspicious Activity Report with the Financial Crimes Enforcement Network and notifies relevant regulators. The firm and its personnel are prohibited from disclosing the existence or content of a Suspicious Activity Report to the subject of the report or to any unauthorized person.

8. Training

All personnel receive AML, KYC, and sanctions training on hire and annually thereafter. Personnel in roles with elevated financial-crime exposure receive role-specific training. Training records are retained for not less than five years.

9. Recordkeeping

Customer identification records, beneficial ownership records, due diligence files, screening records, Suspicious Activity Reports, and training records are retained for the periods required by the Bank Secrecy Act and other applicable laws, in no case less than five years from the date of the relevant transaction or relationship termination.

10. Independent Testing

The firm's AML program is subject to independent testing on an annual basis by the internal audit function or by an external party engaged by the Audit Committee. Findings are reported to the Audit Committee and remediation is tracked through closure.

11. Prohibited Investors

The firm does not accept investments from anonymous investors, shell companies without legitimate business purpose, financial institutions in jurisdictions subject to comprehensive U.S. sanctions, or any person identified on an applicable sanctions list. The firm reserves the right to decline any subscription, restrict transfers, mandatorily redeem an investor, or take other action consistent with applicable law and the relevant fund documents in order to maintain the integrity of the AML program.