1. Purpose

This Privacy Policy (the "Policy") is prepared by Sadoxis Capital Management and outlines how sadoxis capital management collects, uses, discloses, and manages personal information through our website and other interactions with individuals. For information on how we process personal information related to individuals applying for positions or board appointments at Sadoxis Capital Management, please refer to the Sadoxis Capital Management Applicant Privacy Policy.

2. Definitions

"Personal Information" refers to information about an identifiable individual, including names, addresses, email addresses, signatures, opinions about the individual, and other related information. Depending on your jurisdiction, certain business contact information may not be considered Personal Information under applicable privacy laws.

3. Collection and Use of Personal Information

We may collect personal information in the following circumstances:

• When you visit our Website;
• When you visit our facilities;
• When you register to receive communications from Sadoxis Capital Management
• During the management of our investments and due diligence processes;
• In relation to forums, conferences, or other events sponsored by Sadoxis Capital Management;
• During public consultations, surveys, focus groups, or feedback sessions;
• When you contact us with inquiries or comments or otherwise provide us with your personal information.

4. Sharing of Personal Information

We do not disclose, trade, rent, sell, or otherwise transfer personal information without your consent unless specified below:

• Service Providers: We may share personal information with third-party service providers who process data on our behalf, such as website hosting or email distribution.
• Legal Requirements: We may disclose personal information if required or permitted by law, such as responding to valid legal requests or to protect Sadoxis Capital Management's rights and safety.

5. Safeguards and Retention

We implement reasonable administrative, technical, and physical safeguards to protect personal information from unauthorized access, use, modification, or disclosure. Personal information is retained only as long as necessary to fulfill the purposes described or as required by law.

6. Individual Rights

Under applicable privacy laws, you have the right to:

• Access, correct, or delete your personal information;
• Withdraw your consent to certain uses of your personal information;
• Request a copy of the personal information we hold about you.

7. For Individuals in the U.S. and Other Regions

For residents of the United States, sadoxis capital management complies with applicable federal and state privacy laws, including but not limited to the California Consumer Privacy Act (CCPA) and other relevant regulations. Personal information is processed based on legitimate business interests, contractual obligations, legal requirements, or with your consent, as applicable.

8. Links to Other Websites

Our website may contain links to third-party websites. These websites are not under sadoxis capital management's control, and we are not responsible for their privacy practices. We recommend reviewing the privacy policies of any linked websites.

9. Changes to Our Privacy Policy

This Privacy Policy may be updated periodically to reflect changes in our privacy practices or applicable laws. The latest version will always be available on our website, and in some cases, we may notify you via email of significant changes.

For any inquiries, please contact us at: Email: [email protected]

10. Contact Us

Please contact us if:

• You have any questions or comments about this Privacy Policy,
• You wish to access, update, and/or correct inaccuracies or omissions in your personal information, or otherwise exercise your data protection rights.
• You have concerns or complaints about how we or our service providers handle your personal information.

You can reach us via our website at [email protected] or by mail at the following address:

Sadoxis Capital Management Attn: Managing Director, Head of Compliance 225 Liberty Street, 29th Floor New York, NY 10281, U.S.A.

Our collection and use of personal information is required for us to deliver the services and perform the functions described below, and without which we would not be able to undertake certain tasks.

Visiting our Website
Please see the section below titled "Cookies and Additional Information about our Website" for details about the Website's collection, use and disclosure of personal information.

Visiting our Facilities
In accordance with applicable laws, CCTV cameras are installed by Sadoxis to ensure the security and safety of our premises. For more information about our use of CCTV, please refer to Sadoxis CCTV Standard which is available upon request from [email protected].

When we are required or permitted by law to do so, we may collect sensitive personal information relating to health and coronavirus vaccination status of visitors to our premises, in order to protect the health and safety of Sadoxis personnel and visitors to our premises.

Signing Up for Sadoxis Communications
We may provide you with an opportunity to sign-up to receive Sadoxis communications by email or mail, such as news and updates. If you choose to sign-up to receive Sadoxis communications, we may collect contact information such as your email and postal address. You can opt-out of receiving these communications at any time by clicking on the unsubscribe link included in our email communications or by contacting us as described in the Contact Us section below. Please note that if you unsubscribe, you may continue to receive certain non-marketing electronic communications from us.

Managing Investment Activities
In the course of Sadoxis' investment activities, we may collect personal information about individuals with whom Sadoxis works or invests (such as investment advisors or fund managers), or about members of the Boards of Directors (or similar) or management, clients or suppliers of companies or entities in which Sadoxis Investments is considering an investment. The information we collect may include information obtained through background verifications. We collect and use this information in order to conduct due diligence regarding potential investments, investment advisors or fund managers, to manage our investments, to track attendance at board meetings and as required by applicable law. For individuals located in the European Economic Area (EEA), the United Kingdom (UK), or Brazil we use personal information for these purposes (i) in reliance on our legitimate interest under applicable law in operating and improving our business, or (ii) because we are required to do so by applicable law.

Forums, Meetings, Conferences and Other Activities
From time to time, Sadoxis may sponsor forums for discussion, conferences or other similar activities. In the course of these activities, we may collect personal information of registrants such as name, email address, contact information and payment information in order to administer registration for the forum, conference or other activity. For example, Sadoxis may collect the name, municipality or township, province/state and country of residence of individuals who attend any of the Sadoxis Bi-Annual Public Meetings in America. This information is used for security and reporting purposes. For individuals located in the EEA, the UK, or Brazil we use personal information for these purposes in reliance on our legitimate interest under applicable law in administering these events.

Public Consultations, Opinion Surveys, Focus Groups or Feedback
Sadoxis or its authorized survey, polling or other service providers may conduct public consultations, opinion surveys, focus groups or solicit public feedback in which individuals participate to support the fulfilment of our mandate. In the course of these activities, Sadoxis Investments may obtain consent from participants to collect and use personal information such as first and last name, email address, telephone number, and mailing address for the purpose of conducting research and/or public engagement. Reports generated from such public consultation will be provided to Sadoxis in aggregate form and in a manner that does not identify any individual participant.

Call Recording
Subject to applicable law, Sadoxis may monitor and record audio and video conversations with the Sadoxis securities trading desk or with other Sadoxis personnel to ensure accuracy and for record-keeping purposes. For individuals located in the EEA, the UK, or Brazil we use personal information obtained from these conversations in reliance on our legitimate interest under applicable law in ensuring accuracy and maintaining records related to our business.

Social Media
We may offer you the opportunity to engage with Sadoxis Investments or its content on or through third-party social networking websites, plug-ins and applications. When you engage with us on or through third-party social networking websites, plug-ins and applications, you may allow us to have access to certain information associated with your social media account (e.g., name, username, email address, profile picture) to deliver content or as part of the operation of the website, plug-in or application. For individuals located in the EEA, the UK, or Brazil we use this information in reliance on our legitimate interest under applicable law to do so (including to deliver content or as part of the operation of the website, plug-in or application).

Questions, Comments and Complaints
If you contact us with a comment, question or complaint, you may be asked for information that identifies you (such as your name, email address, address and phone number) along with additional information we need to help us promptly answer your question or respond to your comment, question or complaint. We may also retain this information to assist you in the future. For individuals located in the EEA, the UK, or Brazil we use this information in reliance on our legitimate interest under applicable law in communicating with individuals who contact us.

When you visit our websites, we collect your IP (Internet protocol) address and other related information such as device identifiers and characteristics, page requests, browser characteristics, operating system, referring URLs, clickstream data and average time spent on our websites. We collect these types of personal information using automated means, including cookies and pixels.

Cookies are small files that are downloaded to the device you use to visit a website. They are generally used to help improve visitors' experiences on the site, by, for instance, remembering preferences, login information, or otherwise recognizing that they have visited the site previously (or are the same user during a single visit). They are also used by website owners to make improvements to the site based on visitor behaviour. In some cases they are used to collect and store information about specific users. A "pixel," also known as a "web beacon," links web pages to web servers and cookies and may be used to transmit information collected through cookies back to a web server.

Subject to applicable privacy legislation, we only use cookies that are not necessary for our websites to function if you give consent, which is requested when you first visit the websites.
The non-necessary cookies we may use on our websites, and the tracking technologies we may use in our communications and advertisements, are primarily for analytics purposes: to better understand how individuals are moving through the websites, what pages they visit, what Sadoxis Investments emails they open, how long they remain on pages, and so on. We use this information to make improvements to how the websites work and to ensure we meet the information needs of our visitors, including with respect to the effectiveness of our communications.

In accordance with applicable privacy legislation, we also may use third-party advertising cookies, pixels and other tracking technologies to provide you with information about us, or products and services that may be tailored to your interests. Where we use these technologies and services, they:

• Track your online activities over time and across multiple websites and apps by collecting information through automated means.
• Use this information to show you ads that may be tailored to your individual interests.
• May collect information that includes data about your visits to websites that serve our advertisements, such as the pages or ads you view and the actions you take on the websites or apps. This data collection takes place both on our Website and on third-party websites and apps that participate in these ad services.

When we utilize these services, this process helps us track the effectiveness of our marketing efforts. Our websites are not designed to respond to "do not track" signals from browsers. To learn how to opt out of interest-based advertising, please visit the Digital Advertising Alliance and the Network Advertising Initiative. Please also refer to the "Disabling Cookies" section below for information on how to restrict cookies through the settings on your browser.

Some of the cookies we use on our websites are persistent cookies which remain on your computer or other Internet-connected device for a certain period of time after you end your browsing session unless you delete them. Others are session cookies and are deleted when you end your browsing session.

Disabling Cookies
You can choose to prevent cookies from being downloaded to your device by adjusting your cookie consent preferences using our Cookie Settings Centre that can be accessed by using the widget on each page of the site, or blocking some or all of them. However please note that if you do this you may not be able to use the full functionality of the site. You can also delete cookies that have already been downloaded.

If you do wish to restrict or block cookies you can do this through the settings of whatever browser you are using. To find out how click on the appropriate link:
Deleting cookies using Internet Explorer
Deleting cookies using Firefox
Deleting cookies using Chrome
Deleting cookies using Safari and iOS devices

Summary of Tracking Technologies

Google Analytics (www.google.com/analytics/)
Google Analytics is an analytics solution that provides information on how visitors interact with the site. It is used to track things such as how long you spend on the site, which pages you go to, how you get to the site, and which geographic areas you are from.

Google Analytics uses two cookies: The cookie called "_ga" is a persistent cookie that is used to distinguish between visitors to the site. The "_ga_<container-id>" cookie provides information about visitor behaviour on the site and site performance. You can learn more about Google Analytics cookies here.

Meta Conversion Tracking Pixel (www.facebook.com/privacy/policy)
The Meta Pixel is a snippet of JavaScript code that allows us to track visitor activity on our website, including whether users who had received Sadoxis Investments information on one of the Meta services subsequently visited our website, and with which features of our website they engaged. We use the Meta Pixel to collect information that allows us to assess how effective our advertising activities are. In some cases, and only in accordance with applicable privacy legislation, we also may use the Meta pixel to serve advertisements to users that are tailored to their interests based on their online activities and inferred interests, and to develop customized audiences for targeted advertising campaigns.

Siteimprove (www.siteimprove.com)
Siteimprove is an application that provides us with analytics about traffic to our website. It uses a cookie called "nmstat" that is persistent. The cookie contains a randomly generated ID used to recognise the browser when you read a page.

Siteimprove also uses a session cookie (one that is stored in temporary memory and is erased when you close your web browser). This cookie is called "siteimproveses" and is used to track the sequence of pages you view during a visit to the site. For more information about Siteimprove's cookies practices, please visit their website.