CONFLICT OF INTEREST POLICY

Last Updated: March 2026

1. Overview

NHEST TRADING LLC is dedicated to ensuring that all institutional decisions and trading activities are conducted with the highest degree of integrity. This policy outlines our commitment to identifying and managing conflicts of interest that could adversely affect our clients.

2. Management of Interests

We maintain a rigorous separation between our proprietary trading desk and client-managed portfolios. Our automated execution models are designed to provide fair access to liquidity for all participants without favoring proprietary accounts over client accounts.

3. Transparency in Fees

All performance fees and management charges are transparently disclosed in our Terms of Service. NHEST TRADING LLC does not accept hidden commissions or "kickbacks" from third-party brokerages that could influence our execution strategy.

4. Staff Restrictions

Employees and analysts at NHEST TRADING LLC are subject to strict "Personal Account Dealing" rules. All personal trades must be disclosed and must not conflict with the active execution models being deployed for clients.

5. Ongoing Governance

Our governance desk regularly reviews system logs and administrative actions to ensure compliance with this policy. Any identified conflicts are documented and remediated immediately to protect client interests.