499X Capital GmbH – Conflict of Interest Policy Valid as of 30 November 2025

499X Capital GmbH is a privately held company owned 100 % by its Managing Director Dr. Christoph Lymbersky. All investment decisions are made exclusively in the best interest of the company and its shareholders.

Potential conflicts of interest are managed as follows:

  • The Managing Director and all related parties invest personally in the same assets and on the same terms as all other shareholders.
  • No preferential treatment, side letters, or different fee classes exist.
  • Brokerage, custody, and service-provider selection is based solely on cost, security, and execution quality.
  • No soft-dollar arrangements, revenue sharing, or retrocessions are accepted.
  • All personal transactions of the Managing Director in the same asset classes are disclosed annually to shareholders.

By design, the complete alignment of interests between management and investors eliminates material conflicts.